Appendix F

Wilderness Commercial 

Needs Assessments

Kootznoowoo Wilderness Recreation Commercial 

Needs Assessment

Admiralty Island National Monument

Kootznoowoo Wilderness Commercial Needs Assessment Page 1 
Executive Summary

This document applies the criteria of Section 4(d)6 of the Wilderness Act to determine which recreation 

commercial service activities may be necessary in the Kootznoowoo Wilderness Area. 

Commercial services may be performed within the wilderness areas designated by this Act to the 

extent necessary for activities which are proper for realizing the recreational or other wilderness 

purposes of the areas.

This assessment pertains solely to recreation commercial service activities. It does not consider other 

commercial or noncommercial uses. The need for recreation commercial service activities is determined 

by their ability to realize the recreational or other wilderness purposes of the Wilderness Act and their 

compatibility with preserving wilderness character. 

This assessment concludes with a determination of need for five recreation commercial service activities 

in the Kootznoowoo Wilderness. Need was determined with 16 screening questions that assessed 

commercial service activities against the public purposes and compatibility with preserving wilderness 

character as defined in the Wilderness Act of 1964 and consistent with the Alaska National Interest Lands

Conservation Act of 1980 (ANILCA). If recreation or other public purposes are realized while wilderness 

character is upheld, commercial services may be deemed necessary. In order for a positive determination 

of need, the recreation commercial service activity must at a minimum meet the recreation purpose and be 

compatible with preserving wilderness character. The following summarizes the findings. 

Determination of Need for Commercial Service Activities: 

Remote setting nature tour commercial service activities are necessary in the Kootznoowoo 

Wilderness.

Floatplane landing tour commercial service activities are not necessary in the Kootznoowoo 

Wilderness.

Camping commercial service activities are necessary in the Kootznoowoo Wilderness.

Freshwater fishing commercial service activities are necessary in the Kootznoowoo 

Wilderness. 

Hunting commercial service activities are necessary in the Kootznoowoo Wilderness. 

Commercial services may only occur to the extent necessary as mandated by Section 4(d)6 of the 

Wilderness Act. Subsequent site specific commercial use allocation decisions under the National 

Environmental Policy Act will further define commercial service activities (locations, timing of use, 

numbers of visitors, etc.) to ensure the preservation of wilderness character.

INTRODUCTION

This document is a wilderness commercial needs assessment for recreation commercial services in the 

Kootznoowoo Wilderness Area, Admiralty Island National Monument. It applies the criteria of Section 

4(d)6 of the Wilderness Act of 1964 (Wilderness Act) to determine which recreation commercial service

activities may be necessary in the Kootznoowoo Wilderness. This document also applies other specific 

criteria of the Wilderness Act to determine the need for commercial outfitter and guide activities. 

Kootznoowoo Wilderness Commercial Needs Assessment Page 2 
The need for recreation commercial services is determined by assessing the ability of activities to fulfill

the recreational or other wilderness purposes of the Wilderness Act. In addition, commercial service 

activities must be compatible with preserving wilderness character. A determination of need may be 

found where activities fulfill the recreation purpose or other purposes of the Wilderness Act and are 

compatible with preserving wilderness character. The preservation of wilderness character will also be a 

critical factor in further defining site specific constraints in capacity allocation decisions when 

determining ‘the extent necessary’ for commercial service activities. 

This needs assessment is part of a sequential process of administering recreation commercial use on 

National Forest System lands within wilderness. It only pertains to recreation commercial activities and 

does not apply to other commercial or non-commercial uses. Other aspects of administering recreation 

commercial use outside the scope, but tiered to this assessment include: 

National Environmental Policy Act (NEPA) analyzes a proposed commercial outfitter and guide 

allocation of the overall recreation capacity and will establish mitigation measures that balance use with 

protection of the National Forest resource. The decision made in this analysis would define the extent and

amount of commercial recreation use to be authorized. These public planning processes inform decision 

makers of choices among alternative courses of action based upon resource capability and public input.

A prospectus may be necessary to implement NEPA decisions when demand for commercially guided 

recreation opportunities exceeds the available capacity. A prospectus requires commercial operators to 

submit bid applications that meet specific criteria. The Authorized Officer allocates commercial use to 

businesses that best respond to the criteria.

Special use permits authorize individual outfitter and guides within the determined allocation and 

according to established mitigation measures. 

This needs assessment: 

• Determines the need for various activities of commercial outfitter and guiding services based on

fulfilling the purposes of the Wilderness Act and compatibility with preserving wilderness

character within the Kootznoowoo Wilderness.

• Is an internal analysis.

• Does not analyze or mitigate potential environmental impacts from commercial outfitting and

guiding activities.

• Does not determine the extent and amount of recreation commercial use that may be authorized.

The assessment considers the entire Kootznoowoo Wilderness Area. The Kootznoowoo Wilderness Area 

includes all National Forest System lands above mean high tide and excludes areas with reserved rights to 

Kootznoowoo Corporation for development of Thayer Creek Hydro and quiet use and enjoyment of 

corridor lands in Mitchell, Kanalku and Favorite Bays. 

This is intended to be a living document. It is recognized that wilderness conditions and factors that affect 

them may change, as well as market demands for various commercial service activities. When substantial 

changes occur in natural systems and/or commercial recreation service markets, this assessment will be 

updated accordingly. 

This needs assessment is organized into five major sections and appendices to include: 

• Introduction – provides the context and scope of this needs assessment.

• Kootznoowoo Wilderness – provides brief overview of the wilderness qualities and

applicable laws.

• Commercial Service Activities & Public Purposes – defines the commercial service

activities, purposes and screening questions for determining need.

• Wilderness Character – defines wilderness character and provides screening questions

Kootznoowoo Wilderness Commercial Needs Assessment Page 3 
to determine compatibility with activities. 

• Determination of Need for Commercial Service Activities – presents findings for

determination of need.

KOOTZNOOWOO WILDERNESS

Kootznoowoo Wilderness: The Bear Fort 

Walk carefully here. The Tlingit people of Southeast Alaska have long known that brown bear outnumber 

people by a large margin on the rainforest island wilderness known as Kootznoowoo, the “bear fort.” 

Here the brown bear confronts us with our fear of the primeval forest and serves as the ambassador for all 

things wild. If we followed the brown bear through the course of her year, from her rocky alpine den to a 

coastal stream exploding with spawning salmon, we’d discover a vast place known intimately by smell and 

taste. If we followed her tracks along the edge of a meadow to her lingering scent on the bark of a spruce 

tree, we’d inhale her secret message: “I am here, I walk this place”. It is your place to feel the wild pulse 

of the earth, where the ambassador treads on padded feet. Walk carefully. 

-Kootznoowoo Wilderness Niche Statement

Admiralty Island has long been associated with the brown bear (Urus arctos). The original name, The 

Bear Fort, indicates early Tlingit were well aware of the dense population of brown bear that 

distinguishes this island from others. The northern edge of the Kootznoowoo Wilderness lays just 12 

boat-miles south of the capital city of Juneau, Alaska. From here, Kootznoowoo Wilderness stretches 

another 81 miles south to Frederick Sound. Paddlers on the Cross Admiralty Canoe Route cross six lakes 

and find abundant solitude as they traverse from the traditional Tlingit village of Angoon to the historic 

homestead of Allen Hasselborg (the bear man of Mole Harbor), a distance of 27 miles. Totaling 956,255 

acres (about 1,500 square miles) this wilderness supports approximately one bear per square mile by latest 

estimate, one of the densest populations known. 

Coastal forests of massive Sitka spruce and western hemlock dominate, and while Sitka black-tailed deer 

stay well hidden in the dense forest, bald eagles are easily found in treetops along most beaches. Harbor 

seals, Steller sea lions, and humpback whales feed near rafts of sea ducks such as scoters and harlequins. 

The forest floor lays thickly covered with mosses and blueberry, while muskegs open the tall forest 

canopy to sedge and sphagnum bogs. Rocky spires break through along the island's high crest with peaks 

above 3,000 feet. Protected as Admiralty Island National Monument in 1978, almost all but the northern 

end of the island was designated Wilderness in 1980 under the Alaska National Interest Lands 

Conservation Act (ANILCA). Additional lands around Admiralty Cove and Young Lake were added as 

wilderness in 1990 under the Tongass Timber Reform Act (TTRA). 

Bear hunting is a traditional sport attracting international and local interest, especially in the spring. Bear 

viewing is available during the summer at Pack Creek or in other remote bays around the island. Sea 

kayaking is popular in the relatively protected waters of Seymour Canal and in many other bays including 

Mitchell Bay near Angoon. 

Residents of Angoon rely upon Kootznoowoo Wilderness for subsistence activities, particularly along 

Chatham Strait. Kake and Petersburg residents hunt deer and brown bear at the southern edge of the

island. Deer hunting in Seymour Canal and northern Admiralty Island is popular with Juneau residents. 

Several private inholdings and 19 cabins under permit provide a few with year-around homes and most 

others with seasonal camps. 

The Pack Creek Zoological Area (PCZA), located in Windfall Harbor and Swan Cove was first 

recognized in the 1997 Tongass Land and Resource Management Plan and subsequent revisions as a 

special management area. The PCZA is famous for the incredible number of brown bears that inhabit its 

exceptional and diverse landscape. People come from all over the United States and around the world to 

view bears in this wilderness setting. A wilderness permit is required for visitors to the Pack Creek Bear 

Kootznoowoo Wilderness Commercial Needs Assessment Page 4 
Viewing Area. The bear viewing area is cooperatively managed with the Alaska Department of Fish & 

Game. The site allows a maximum of 24 visitors a day during the peak season, of which half are 

allocated to commercial recreation service providers. A Prospectus for the bear viewing area and larger 

PCZA was completed in 2012. The PCZA currently has nine recreation commercial service providers that 

offer an array of remote setting nature tours (wildlife viewing, photography) and camping. 

In whole, the Kootznoowoo Wilderness currently has approximately 34 outfitter and guide operations that 

offer a wide variety of activities including remote setting nature tours (hiking, paddling, exploring, 

wildlife viewing, etc.), camping, freshwater fishing, and hunting. Currently outfitter and guide service 

providers are allowed to operate on shore along the entire marine coast of the wilderness area, except for 

within one mile of Admiralty Cove. The Admiralty Cove area has been excluded from authorized outfitter 

and guide use due to its close proximity and relatively easy access from Juneau. This area is already well 

used by the general public (non-commercial users). In addition, there are no outfitter and guide service 

providers, except Thayer Lake Lodge, authorized to operate within the interior lands (generally 1⁄2 mile or 

more from mean high tide) or lakes of the Kootznoowoo Wilderness due to no requests to conduct this 

activity or environmental analysis in place to authorize use. Point-to-point transport to more than 20 

cabins and shelters on lakes or along the shoreline can be provided by commercial floatplane operators 

without a permit.

The Wilderness Act and the Alaska National Interest Lands 

Conservation Act

The Wilderness Act authorizes Congress to designate wilderness areas amidst public lands managed by 

federal agencies. The goal of the Wilderness Act is to secure for present and future Americans the 

benefits of an enduring wilderness resource. The law achieves this goal by affirming qualities for which 

wilderness is to be administered and by limiting uses that degrade those qualities. 

The passage of ANILCA established 14 wilderness areas on the Tongass National Forest; including the 

Kootznoowoo Wilderness (known at that time as “Admiralty Island National Monument Wilderness”). 

ANILCA also included exceptions to the Wilderness Act that apply to these wilderness areas. Specific 

sections that apply to the Kootznoowoo Wilderness and this assessment include: 

Section 503(j) allows for the Thayer Lake Lodge special use permit to be renewed as 

necessary for up to the lifetime of the permittee, or the surviving spouse or child of such 

permittee, whoever lives longer. 

Section 506(3)(E) allows for the Kootznoowoo Corporation to consult and cooperate with 

the Secretary of Agriculture in the management of Mitchell, Kanalku and Favorite Bays 

and their immediate environs and enter into cooperative arrangements as may further the 

purposes of ANILCA. 

Section 1110(a) allows for the use of airplanes, motorboats, and snowmachines (during 

periods of adequate snow). 

Section 1303(b)(3) allows for the establishment and continued use of existing 

administrative sites and visitor facilities.

Section 1307(a) allows for the continuance of visitor services that were operating on 

January 1, 1979 in designated conservation system areas (of which Kootznoowoo 

Wilderness is one); however, there are no present day commercial operations that were 

authorized use within the bounds of the Kootznoowoo Wilderness Area on that date. 

This section also provides a preference for providing visitor services within conservation 

system units; except for fishing and hunting; to Native Corporations and local residents. 

Section 1315(c) allows for the permitting, maintenance, replacement, and continued use 

of public use cabins. 

Kootznoowoo Wilderness Commercial Needs Assessment Page 5 
Section 1315(d) allows for construction of new cabins if necessary for the protection of 

public health and safety. 

Section 1316 (a) allows for existing and future establishment of temporary structures 

necessary for the taking of fish and game subject to reasonable regulation to insure 

compatibility, the continuance of existing uses, and the future establishment, and use, of 

temporary campsites, tent platforms, shelters, and other temporary facilities and 

equipment directly and necessarily related to such activities. 

Section 1316(b) allows for the denial of the temporary facilities if the use of equipment 

or facilities is determined to be a significant expansion of existing uses or facilities which 

would be detrimental to the purposes for which the Kootznoowoo Wilderness was 

established, including the wilderness character. 

Other than these exceptions expressed in ANILCA, commercially guided uses within Kootznoowoo 

Wilderness are administered according to the Wilderness Act of 1964 (ANILCA Section 707). 

The principle administrative charge of the Wilderness Act is to preserve wilderness character. Agencies 

have defined wilderness character using the descriptive aspects found within the law: untrammeled; 

undeveloped; natural; outstanding opportunities for solitude or a primitive and unconfined type of 

recreation, and unique features of ecological, geological or other features of scientific, educational, scenic 

or historical value. Generally speaking, actions or uses that are compatible with these qualities may be 

allowed in wilderness. 

The Wilderness Act also limits uses that would degrade the qualities of wilderness character. With 

specific exceptions in the Wilderness Act, it prohibits commercial enterprise, permanent roads, and except 

as necessary to meet minimum requirements for the administration of the area for the purpose of this Act, 

temporary roads, motor vehicles, motorized equipment or motorboats, landing of aircraft, other forms of 

mechanical transport, or installations and structures. 

Commercial services, the subject of this needs assessment, are one of the possible exceptions to the 

prohibition on commercial enterprise per Section 4(d)6 of the Wilderness Act: 

Commercial services may be performed within the wilderness areas designated by this Act to the extent 

necessary for activities which are proper for realizing the recreational or other wilderness purposes of the 

areas. 1

1

 Wilderness Act, 16 USC 1133(d)(5).

Kootznoowoo Wilderness Commercial Needs Assessment Page 6 
COMMERCIAL SERVICE ACTIVITIES & PUBLIC PURPOSES 

The Wilderness Act was redrafted sixty-five times with intense scrutiny on its wording. The deliberate 

language of Section 4(d)6 reflects this extensive editing. As Section 4(d)6, in the context of the whole law 

and its mandate to preserve wilderness character, forms the basis for determining the need for commercial 

services, an examination of its specific language is merited. 

The following sections interpret Section 4(d)6 of the Wilderness Act and discuss how it applies to 

outfitter and guide commercial services in the Kootznoowoo Wilderness: 

Commercial services may be performed within the wilderness areas designated by this Act to the 

extent necessary for activities which are proper for realizing the recreational or other wilderness 

purposes of the areas.

(1) Commercial services

The Code of Federal Regulations provides guidance as to the scope of commercial services to be 

considered under Section 4(d)6 by stating that:

The Chief, Forest Service, may permit . . . commercial services within National Forest Wilderness 

to the extent necessary for realizing the recreational or other Wilderness purposes, which include, 

but are not limited to, the public services generally offered by packers, outfitters, and guides.2

Outfitter and guide services addressed in this needs assessment include remote setting nature tours 

(hiking, paddling, skiing, wildlife viewing, photography, exploring, sightseeing, cultural tours, etc.), 

floatplane landing tours, camping, freshwater fishing, and hunting. These services represent the range of 

activities currently sought after by the public who visit the Tongass National Forest. Not all of these 

activities are currently authorized within the Kootznoowoo Wilderness, but represent reasonably

foreseeable future demands for services. Outfitter and guide activities that are currently not authorized by 

the Forest Service in the Kootznoowoo Wilderness include skiing and floatplane landing tours.

(2) May Be Performed

The word “performed” means “to carry out or fulfill” and is accomplished by guide services under permit 

from the Forest Service. The word “may” has a specific legal meaning: “action is optional.”3 Hence the 

managing agency or authorized line officer may opt to permit or not to permit commercial services, or to 

permit some services but not others. 

(3) Within Wilderness Areas Designated By This Act

This language refers to the Wilderness Act and subsequent enabling wilderness legislation, such as 

ANILCA, which designated the Kootznoowoo Wilderness, and the TTRA which expanded the wilderness 

area by amending ANILCA. 

(4) To The Extent Necessary

The overriding constraint on commercial services (and all types of visitor use) in wilderness is the 

mandate to preserve wilderness character. Human influences that impair wilderness character are to be 

minimized so that the natural conditions are protected, and the benefits of the wilderness resource (social, 

biological, and physical) are available to future generations. 

2 36 CFR 293.8, Permanent structures and commercial services.

3

 Forest Service Manual, 1110 Directives, exhibit 1110.8.

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“Extent” means “scope” or “magnitude.”4

 The scope or magnitude of commercial services can be gauged 

quantitatively (the number of permits issued; the number of commercial clients authorized), spatially 

(where operations are necessary or authorized) and temporally (when operations are authorized). Extent is 

further defined and constrained by the capacity or capability of the wilderness to support the activity 

without impairment to wilderness character.

“Necessary” commercial services are those that serve the public’s need to experience wilderness and 

support management objectives within the capability of the wilderness resource. Commercial service 

activities are potentially necessary if they help achieve the public purposes of wilderness without 

impairment of wilderness character. 

Need for outfitter and guide commercial services can only occur to the degree where, when and in 

numbers where wilderness character is unimpaired. Need is defined by a shortage of opportunities for the 

public to experience wilderness and/or an agency need for assistance with implementation of management 

objectives which can be addressed through commercial service providers.

(5) For Activities Which Are Proper for Realizing the Recreational or Other Wilderness

Purposes of the Areas

Proper activities are those which are compatible with the goals of the Wilderness Act. The paramount 

goal is the preservation of wilderness character. This includes the use and enjoyment of wilderness by 

present and future generations. Commercial services can fulfill both stewardship and service roles by 

engaging in proper and purposeful activities. 

 Activities conducted responsibly would preserve the integrity of the wilderness resource. At a minimum, 

such activities would embrace outdoor ethics to minimize impacts and avoid prohibited means that 

degrade wilderness character, excepting allowable ANILCA stipulations. The stewardship role can be 

filled further by actively educating clients regarding conservation issues and the benefits of wilderness in 

times of environmental stress, as well as by actively involving clients in citizen science projects to help 

administer wilderness. 

Activities enhance people’s use and enjoyment of wilderness when wilderness or recreation purposes are 

realized. Regarding the commercial service activities, this needs assessment examines remote setting 

nature tours, floatplane landing tours, camping, hunting and freshwater fishing. These activities may be 

provided if determined to be compatible with the outstanding opportunities for solitude or a primitive and 

unconfined type of recreation the Wilderness Act seeks to provide. Outfitter and guides play a meaningful 

role in teaching the skills necessary to enjoy historic and recreational pursuits and in interpreting the 

scenic, scientific, educational, conservation and historical values of the visited wilderness area. 

This section concludes with examining in greater detail:

I. Commercial Outfitter and Guide Service Activities

II. Recreational or Other Wilderness Purposes

Commercial Outfitter and Guide Service Activities

Activities considered in this needs assessment only include those that occur above mean high tide on 

National Forest System lands. Also not included is strictly point-to-point transportation services provided 

at a competitive fee that is not a tour or part of a package trip. Many activities that take place within the 

Kootznoowoo Wilderness, above mean high tide, are done in combination with activities outside the 

wilderness on state jurisdiction submerged lands and marine waters. The activities considered in this 

needs assessment include 1) remote setting nature tours, 2) floatplane landing tours, 3) camping, 4) 

freshwater fishing, 5) hunting.

4

 Webster’s 9th New Collegiate Dictionary, 1990, page 440.

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Remote setting nature tours encompass, but are not limited to, a wide variety of day use activities such as 

hiking, paddling, skiing, wildlife viewing, photography, exploring, sightseeing, and cultural tours. All of 

these activities, except skiing, are currently sought after by wilderness visitors and offered by commercial 

service providers within the Kootznoowoo Wilderness. The size of these groups tends to be the largest of 

all activities with a maximum of 12 people at one time. Visitors may spend from a few minutes to many 

hours participating in these activities. Desirable attributes for these activities include accessible sections 

of shoreline, maintained trails and facilities, and unique features of geological, ecological or cultural 

interest. Specific areas within the Kootznoowoo Wilderness that are sought after for these activities 

include the Pack Creek Zoological Area, Cross Admiralty Canoe Route, Brothers Islands, Seymour 

Canal, Mitchell Bay and other numerous bays, inlets and waterways along the coast line. Access to the 

wilderness is only achieved by boat or aircraft. Travel within the wilderness is typically by paddle craft or 

foot. 

Floatplanes are a common and allowed method of transport for recreation use on the Tongass NF. 

However, the authorization of floatplane landing tours on the Tongass is limited and has not been 

authorized within the Kootznoowoo Wilderness. A floatplane landing tour is defined in this assessment as 

a day-use activity that predominantly involves viewing natural features by air and landing once or 

multiple times within the wilderness and returning back to its point of origin. It typically involves a party 

of six to twelve people. Visitors typically spend only a few minutes to several hours on land participating 

in a remote setting nature tour activity. This activity does not include authorized point-to-point floatplane 

transport used as an ancillary service to another commercial service provider for activities such as remote 

setting nature tours, hunting, fishing or camping. 

Camping is defined as overnight use within the wilderness. Daytime activities may involve boating or 

kayaking on marine waters or remote setting nature tours, hunting or freshwater fishing within the 

wilderness. This use depends on sites amenable to camping such as level ground, accessible beach, 

availability of water, secure boat anchorage or storage, a food cache site, minimal signs of use by bears, 

and so on. Popular camping locations include sections of accessible marine shoreline, public use cabins, 

Pack Creek Zoological Area, and the Cross Admiralty Canoe Route. Commercial camping use within the 

Kootznoowoo Wilderness can be characterized as light, and primarily dispersed along the marine 

shoreline zone. 

Freshwater fishing includes both catch-and-take and catch-and-release methods under state sport fishing 

regulations (excludes commercial and subsistence fishing). This use depends on places and times where 

anadromous and resident fish are located. Freshwater fishing activities may be day use, or encompass 

multiple days. Anglers tend to seek out areas with more solitude and their group sizes are typically 

smaller than those of remote setting nature tour user groups. Popular guided freshwater fishing locations 

within the Kootznoowoo Wilderness include Wheeler Creek, Salt Lake/Hasselborg Creek, King Salmon 

River, and other numerous streams accessed from the marine shoreline. Currently there are no day use 

outfitter and guided fishing activities that originate from freshwater access points (i.e. fly-in lakes).

Hunting includes the hunting of brown bear, deer, and waterfowl, although most guided hunting in 

Kootznoowoo Wilderness is for brown bear. This use depends on places and times where game occur and 

must comply with state regulations. State regulations require a registered guide or next of kin for 

nonresident brown bear hunters. Additionally, hunting requires a high degree of solitude for safety and 

practical reasons (undisturbed wildlife). This use typically reflects a boat-based guiding operation that 

thoroughly explores a bay or an expanded area of marine shoreline for the duration of the hunt. Currently 

there is only one outfitter and guide service that utilizes an on-shore camp as their base of operations. 

Groups tend to be smallest in size (2.0 clients per group) to minimize disturbance and competition and to 

maximize chances of success. The brown bear hunting season opens for a few weeks in the spring and fall 

and is closed the remainder of the year.

Kootznoowoo Wilderness Commercial Needs Assessment Page 9 
Recreational or Other Wilderness Purposes

Activities provided by outfitters and guides in wilderness must support the recreational or other 

wilderness purposes as defined in the Wilderness Act and enabling legislation. The “recreational or other 

wilderness purposes” clause refers to uses supported in the Wilderness Act:

Except as otherwise provided in this Act, wilderness areas shall be devoted to the public 

purposes of recreational, scenic, scientific, educational, conservation, and historical use.5

[emphasis added]

Collectively, these purposes may be referred to as the “public purposes” of the Wilderness Act. 

ANILCA describes similar purposes and values: 

§101. (a) In order to preserve for the benefit, use, education and inspiration of present and future

generations certain lands and waters in the State of Alaska that contain nationally significant natural,

scenic, historic, archeological, geological, scientific, wilderness, cultural, recreational, and wildlife values,

and units described in the following titles are hereby established.

These values are covered within the public purposes of the Wilderness Act examined here and within the 

wilderness character qualities examined later.

The Wilderness Act provides for certain limitations on commercial ventures. Commercial services in 

wilderness must realize the public purposes of wilderness. Drawing a clear connection between 

commercial service activities and purposes is the basis of determining the need for commercial services. 

Broadly speaking, activities provided by commercial services for realizing public purposes will expand 

the capacity of the managing federal agency to administer wilderness areas “for the use and enjoyment of 

the American people in such manner as will leave them unimpaired for future use and enjoyment as 

wilderness, and so as to provide for the protection of these areas, the preservation of their wilderness 

character, and for the gathering and dissemination of information regarding their use and enjoyment as 

wilderness....”6 Fulfillment of these purposes are further achieved by reviewing operating plans, and 

completing field inspections and/or client evaluations. More specifically, each purpose must be discussed

individually to assure common understanding as to what realizing the purpose means. Descriptions of the 

public purposes and the screening questions for realizing them in the Kootznoowoo Wilderness follow. 

Recreational

The recreational use purpose of wilderness includes participation and/or instruction in activities that are 

traditional in the Kootznoowoo Wilderness such as hiking, backpacking, canoeing, skiing, wildlife 

viewing, hunting, and fishing. There is a distinct qualitative aspect to the recreational purpose of 

wilderness: 

An area of wilderness if further defined to mean in this Act an area ... which ... has outstanding 

opportunities for solitude or a primitive and unconfined type of recreation ....7 [emphasis added]

National Forest Wilderness resources shall be managed to promote, perpetuate, and, where necessary, 

restore the wilderness character of the land and its specific values of solitude, physical and mental 

challenge, scientific study, inspiration, and primitive recreation.8 [emphasis added]

5

 Ibid, 16 USC 1133(b). 6

 Wilderness Act, 1964, 16 USC 1131 (a). 7

 Wilderness Act, 1964, 16 USC 1131(c).

Kootznoowoo Wilderness Commercial Needs Assessment Page 10
This qualitative aspect is realized if outfitter and guides offer activities in a manner that clients can enjoy 

outstanding opportunities for solitude or primitive and unconfined recreation, including the values of 

inspiration and physical and mental challenge. 

Wilderness in Alaska can be very remote, challenging and not easily accessible to the general public. 

Specialized skills, knowledge and equipment are often required for access to recreation activities within 

Alaska wilderness areas. Outfitter and guides offer the opportunity to fulfill the recreation purposes of the 

Wilderness Act by providing services that assist in overcoming extraordinary challenge and allow the 

general public to access recreation opportunities. Aspects to consider are the technical and specialized 

needs to access wilderness and the distance from population centers. 

Recreational purpose screening questions: 

Rp1 - Do the commercial service activities require an extraordinary degree of specialized skill, equipment 

and challenge that inhibits access and enjoyment by the majority of the general public? 

Rp2 - Do the commercial services align with recreation pursuits that are traditional within the 

Kootznoowoo Wilderness? 

Scenic

The scenic purpose covers appreciation of the natural grandeur of the wilderness, including landscape, 

soundscape, flora and fauna. Commercial services may offer activities that support this purpose by 

allowing clients to appreciate these wild sights and sounds on their own terms. The opportunity to view 

these natural wonders often invokes a sense of spirituality within. It allows visitors to experience being a 

part of something much bigger and more complex, but intangible. 

Scenic purpose screening questions: 

Sp1 - Do the commercial service activities enhance clients’ appreciation of the aesthetics of the 

wilderness? 

Sp2 - Do the commercial service activities invoke opportunities for spirituality and/or allow for deep 

connections with nature uninhibited by modern civilization? 

Scientific 

Activities offered by commercial outfitter and guide services may be able to assist with research studying 

wildlife, vegetation, geology or other aspects of wilderness. “Citizen Science” trips embody this purpose 

well. Outfitter and guided activities might assist State Fish & Game Departments or other organizations 

with animal studies, either reporting field observations or providing mandatory or voluntary harvest 

information. Activities should offer clients the opportunity to be involved in scientific study to the 

greatest degree possible.

Scientific purpose screening questions: 

Scp1 - Do the commercial service activities provide opportunities to assist with scientific studies or 

involve the scientific process of studying nature? 

8

 Title 36, Code of Federal Regulations, Part 293.2.

Kootznoowoo Wilderness Commercial Needs Assessment Page 11
Educational

A key role of the outfitter and guide is to enhance client enjoyment and use of wilderness. This entails a 

teacher-student relationship that imparts knowledge and skills from outfitter and guides to clients. This 

also involves interpretation which attempts to forge emotional connections between clients and nature. 

Commercial service activities may realize the educational purpose by educating clientele as to the purpose 

and value of wilderness. Tongass National Forest policy requires all wilderness commercial service 

providers to educate their clients about the history, purpose and values of the National Wilderness 

Preservation System as well as the specific wilderness area visited. 

Effective teaching occurs with the realization that wilderness offers an array of educational opportunities 

spanning the human and natural history of our country. Outfitters and guides can teach their clients skills, 

arts, history, biology, geology and other topics during wilderness excursions. Teaching occurs by 

connecting clients to nature, mentoring them and expanding their understanding and appreciation. 

Often, outfitter and guides use the art of interpretation to engage with clients about the natural wonders. 

Interpretation is more than merely providing facts such as the names, elevations and ages of distinct 

features. Interpretation seeks to forge emotional connections to nature through direct experience that 

fosters appreciation of natural systems and by encouraging people to record their appreciation through 

photos, paintings, writings or other expressions. 

Educational purpose screening questions: 

 Ep1 - Do the commercial service activities offer opportunities for education and interpretation about 

certain values of the Kootznoowoo Wilderness such as cultural, ecological or geological in a way that 

fosters connections to nature? 

Conservation

The conservation purpose may be realized from activities that provide local and global perspectives on 

conservation issues. The first ensures that activities are conducted in such a way that the wilderness 

resource remains unimpaired for present and future generations. This can be accomplished by adhering to 

laws and regulations and by practicing outdoor ethics that protect the wilderness character. Outfitter and 

guide activities should offer opportunities to not only adhere to regulations and ethics, but provide 

explanation as to why such regulations and ethics are in place. 

Examples of local conservation regulations and ethics include: state statutes that govern hunting and 

fishing in order to maintain sound populations; permit requirements that prevent overcrowding and 

resource damage, and the closure of bear hunting within the Pack Creek Zoological Area. Outdoor ethics 

include: Leave No Trace practices, proper hunting and fishing ethics and proper wildlife viewing ethics. 

The second means of realizing the conservation purpose is to educate clients about the valuable and 

positive role of wilderness on a planet experiencing climate change, mass extinction, biodiversity loss, 

habitat fragmentation, pollution and other serious plights. The Kootznoowoo Wilderness is recognized by 

the United Nations Education, Scientific and Cultural Organization as part of an international network of 

Biosphere Reserves devoted to conservation of nature and scientific research. It provides a standard 

against which can be measured the effects of man’s impact on the environment. Outfitter-guides may

offer activities that educate their clients as to how the values of wilderness extend beyond the immediate 

personal experience to benefit the broader world community and future generations.

Citizen stewardship activities realize the conservation purpose to an even greater degree by participating 

in wilderness stewardship. These can range from beach clean-ups to treating invasive weeds to trail 

maintenance to monitoring solitude. There are numerous ways in which commercial service activities can 

assist agency wilderness stewardship objectives. 

Kootznoowoo Wilderness Commercial Needs Assessment Page 12
Conservation purpose screening questions: 

 Cp1 - Do the commercial service activities adhere to laws, regulations and outdoor ethics that protect and 

support wilderness character? 

Cp2 - Do the commercial service activities provide opportunities for clients to learn why certain laws, 

regulations and ethics are in place for conservation concerns?

Cp3 - Do the commercial service activities offer opportunities to engage in citizen stewardship projects

and/or provide context to larger world conservation concerns?

Historical

Commercial service activities may realize the historical purpose of wilderness in two manners: by 

assisting with archeological endeavors and/or by connecting people to the human roots of an area. 

Participating in archeological endeavors should always involve authorized archeologists. It could include 

projects such as restoring a historical site or methodically inventorying and recording an area for signs 

such as pictographs or petroglyphs. It should be recognized that it is important to respect local and/or 

indigenous concerns and that it is inappropriate to publicize certain archeological sites. 

Regarding connecting people to their roots, activities can offer clients opportunities to learn about the 

human history of an area, from the indigenous peoples to explorers to settlers to contemporary locals. 

History can be taught through lectures, story-telling, books, maps and photos or local experts. 

Additionally, for those historic sites protected from disturbance which are visited by commercial 

operations, the outfitter and guides take a stewardship role to preserve the integrity of the site by 

protecting site qualities and reporting any disturbances.

Historical screening questions: 

Hp1 – Do the commercial service activities offer opportunities to foster a connection between local 

human habitation and use of the wilderness and its other ecological values?

Wilderness Character

In order to determine need, commercial outfitter and guide service activities must also be compatible with 

the preservation of wilderness character as defined in the Wilderness Act. This assessment describes the 

wilderness character for the Kootznoowoo Wilderness and determines whether the outfitter and guide 

activities are compatible with its preservation for future generations. 

This assessment determines compatibility with the Wilderness Act and screens out inappropriate 

activities; it does not analyze the environmental effects of outfitter and guide activities on wilderness 

character. That analysis is reserved for an environmental analysis, which will be used to define site 

specific constraints (i.e. locations, group sizes, service days, time restrictions, etc.) to further define ‘the 

extent necessary’ to preserve wilderness character.

Wilderness character is a complex idea. It considers a wide variety of qualities, local and national;

tangible and intangible. Federal land management agencies charged with administering wilderness have 

identified five qualities that comprise wilderness character, largely taken from the Wilderness Act Section 

2(c): 

1. Natural

2. Outstanding Opportunities for Solitude or a Primitive and Unconfined Type of

Recreation

Kootznoowoo Wilderness Commercial Needs Assessment Page 13
3. Undeveloped

4. Untrammeled

5. Other features of value

In order to preserve wilderness character, the characteristics and values of the individual wilderness area 

must also be further defined and sustained. The characteristics and values which articulate wilderness 

character for the Kootznoowoo Wilderness, Admiralty Island National Monument are described in 

ANLCA Section 101(a) and Section 503(c). 

Section 101(b)... to preserve wilderness resource values and related recreational opportunities including 

but not limited to hiking, canoeing, fishing, and sport hunting, within large arctic and subarctic wildlands 

and on freeflowing rivers;9

Section 503(c). Subject to valid existing rights and except as provided in this section, the National Forest 

Monuments (hereinafter in this section referred to as the “Monuments”) shall be managed by the Secretary 

of Agriculture as units of the National Forest System to protect objects of ecological, cultural, geological, 

historical, prehistorical and scientific interest.

This assessment is organized to consider the wilderness character for the Kootznoowoo Wilderness under 

each nationally defined quality. Like the previous section, each wilderness character quality will conclude 

with a screening question used to determine the need for commercial service activities.

Natural

The natural quality refers to the condition of the biotic and environmental elements of wilderness: 

1. Natural. Wilderness ecological systems are substantially free from the effects of modern civilization.

This quality is degraded by many things, such as loss of indigenous species, occurrence of nonindigenous

species, alteration of ecological processes such as waterflow and fire regimes, effects of climate change,

loss of dark skies, and occurrence of artificial sounds. It is preserved or improved, for example, by

controlling or removing nonindigenous species or restoring ecological processes. 10

The Kootznoowoo Wilderness includes notable wildlife populations of brown bear, nesting bald eagles,

and deer. Also important for the entire ecosystem, some of which are not within wilderness, are marine 

species such as congregations of humpback whales, and haul-outs for sea lion and harbor seal. The 

wilderness has exceptionally clean air and water that support the abundance of salmon streams important 

to the island ecosystem. 

However, some challenges to naturalness do exist with one salmon stream at Kanalku Bay with depressed 

stocks of sockeye salmon due in part to human harvest. Other challenges to naturalness include the 

presence of 18 known invasive plant species at 162 sites. Nesting birds such as Black Oystercatchers 

(Haematopus bachmani) are sometimes disrupted by boaters and paddlers who visit small islands. Some 

brown bear are impacted by the availability of human garbage or the displacement caused by temporary 

encroachment into critical habitat (e.g. estuarine sedge marshes during the spring). 

Outfitter and guide services play an important role in protecting natural aspects of Kootznoowoo 

Wilderness by helping clients to understand wildlife sensitivities, game laws, and best management 

practices. Outfitter and guides can also prevent disturbance or over-harvest of fish and game species, and 

they can educate about invasive species. 

9 ANILCA, 1980, 16 USC 3101

10 Landres, P., Vagias, W. & Stutzman, S. Using wilderness character to improve wilderness stewardship. Park 

Science, Volume 28, Number 3, Winter 2011-2012, ISSN 1090-9966. National Park Service, U.S. Department of 

the Interior, Natural Resource Stewardship and Science, Office of Education and Outreach, Lakewood, Colorado.

Kootznoowoo Wilderness Commercial Needs Assessment Page 14
Natural character screening question: 

Nc1 - Are commercial service activities compatible with preserving the natural character of Kootznoowoo 

Wilderness?

Outstanding Opportunities for Solitude or a Primitive and Unconfined 

Type of Recreation

As already noted under “Purposes” of Wilderness, Outstanding Opportunities for Solitude or a Primitive 

and Unconfined Type of Recreation help define wilderness character and are affected by management 

decisions in the following way:

2. Solitude or a primitive and unconfined type of recreation. Wilderness provides outstanding

opportunities for solitude or primitive and unconfined recreation. This quality is primarily about the

opportunity for people to experience wilderness, and is influenced by settings that affect this opportunity. It

is preserved or improved by management actions that reduce visitor encounters and signs of modern

civilization inside the wilderness. In contrast, this quality is degraded by agency-provided recreation

facilities, management restrictions on visitor behavior, and actions that increase visitor encounters. 11

Kootznoowoo Wilderness contains approximately 1,500 square mile of wildland preserved in its natural 

state. Opportunities for solitude or a primitive and unconfined type of recreation abound. Certain discrete 

areas within the wilderness, such as the Pack Creek Zoological Area, marine shoreline zone, and others 

with developed trails and cabins may offer fewer opportunities for this type of experience. The Monument 

staff actively monitor for conditions of solitude. These areas under threat of losing this aspect of 

wilderness character will be considered in future NEPA decision making processes. 

Outfitter and guide activities can enhance the wilderness experience quality for visitors, contributing to 

people’s use and enjoyment of wilderness; and outfitter and guides can mitigate visitor impacts leaving 

such outstanding opportunities unimpaired. Where commercial service activities occur often, in numbers, 

or with a large footprint (spread out, loud noise, bright lights, lingering exhaust), the outstanding 

opportunities for solitude or a primitive and unconfined type of recreation quality suffers. As noted in a 

recent threat analysis prepared for Kootznoowoo Wilderness “If not properly planned and managed, 

commercially guided recreation activities can negatively affect outstanding opportunities for solitude, or 

primitive and unconfined experiences, as well as other aspects of wilderness character. “(source: 

Kootznoowoo Wilderness Information Needs Assessment, 2011) 

Outstanding opportunities for solitude or a primitive and unconfined type of recreation 

character screening questions: 

Oc1 - Are commercial services activities compatible with preserving opportunities for solitude, challenge, 

decision-making and self-reliance? 

Oc2 – Are commercial service activities compatible with preserving primitive or unconfined type of 

recreation experiences?

Undeveloped

The undeveloped quality is essential to primeval wilderness which contrasts with those areas where 

expanding settlement and growing mechanization have occupied and modified the land:

11 Landres, P., Vagias, W. & Stutzman, S. Using wilderness character to improve wilderness stewardship. Park 

Science, Volume 28, Number 3, Winter 2011-2012, ISSN 1090-9966. National Park Service, U.S. Department of 

the Interior, Natural Resource Stewardship and Science, Office of Education and Outreach, Lakewood, Colorado.

Kootznoowoo Wilderness Commercial Needs Assessment Page 15
3. Undeveloped. Wilderness retains its primeval character and influence and is essentially without

permanent improvement or modern human occupation. This quality is influenced by what are commonly

called the “Section 4c prohibited uses,” that is, the presence of modern structures, installations, habitations,

and use of motor vehicles, motorized equipment, or mechanical transport. The removal of structures and

not conducting these prohibited uses preserve or improve this quality. In contrast, the presence of structures

and prohibited uses degrades this quality, whether by the agency for administrative purposes, by others

authorized by the agency, or when there are unauthorized uses. 12

ANILCA specifically allowed for the continued use of airplanes, motorboats, and snowmachines (during 

periods of adequate snow cover) for traditional activities and travel to and from villages and homesites. 

These ANILCA exceptions do not alone constitute a degradation of the Undeveloped Quality.13 

The Kootznoowoo Wilderness is primarily undeveloped, but does have some Forest Service infrastructure 

to accommodate resource protection, public use and safety. The Kootznoowoo Wilderness contains 28 

miles of trail, 14 public use cabins, nine public use shelters, an administrative camp in the PCZA and 

radio repeater on Windfall Mountain. In addition, other non-Forest Service developments are permitted 

which include 19 private recreation cabins, one resort, and three communication sites. There are no 

authorized permanent structures or installations, aside from Thayer Lake Lodge, that support outfitter and 

guide activities.

Undeveloped character screening question: 

Uc1 - Are commercial services activities compatible with preserving the undeveloped character by not 

relying on developments or motorized equipment and mechanical transport not specifically allowed under 

ANILCA?

Untrammeled 

“Untrammeled” is also defined as “unfettered”: 

4. Untrammeled. Wilderness is essentially unhindered and free from the actions of modern human control

or manipulation. This quality is influenced by any activity or action that controls or manipulates the

components or processes of ecological systems inside the wilderness. Management actions that are not

taken support or preserve the untrammeled quality, while actions that are taken degrade this quality, even

when these actions are taken to protect resources, such as spraying herbicides to eradicate or control

nonindigenous species or reducing fuels accumulated from decades of fire exclusion. 14

ANILCA again allows for exceptions to actions that may impair the untrammeled wilderness character 

quality. Specific exceptions applicable to the Kootznoowoo Wilderness include the taking of fish and 

wildlife, and fish habitat enhancement. Currently within the wilderness there are three non-commercial 

activities authorized through ANILCA exceptions that include the Kanalku fish weirs, Kanalku fish 

habitat enhancement and collaring bears within the PCZA. 

For recreation commercial service activities, habituation of bears at the Pack Creek Bear Viewing Area 

can be constituted as an activity that degrades the untrammeled character. The habituated bears at Pack 

12 Landres, P., Vagias, W. & Stutzman, S. Using wilderness character to improve wilderness stewardship. Park 

Science, Volume 28, Number 3, Winter 2011-2012, ISSN 1090-9966. National Park Service, U.S. Department of 

the Interior, Natural Resource Stewardship and Science, Office of Education and Outreach, Lakewood, Colorado.

13 Note, however, that noise, lights and emissions from such vehicles may degrade outstanding opportunities for 

solitude. Lower profile vehicles are more conducive to preserving wilderness character in this regard. This is not 

much different than noting that while people may visit wilderness, at a certain magnitude (of numbers or 

concentration), crowdedness degrades solitude.

14 Landres, P., Vagias, W. & Stutzman, S. Using wilderness character to improve wilderness stewardship. Park 

Science, Volume 28, Number 3, Winter 2011-2012, ISSN 1090-9966. National Park Service, U.S. Department of 

the Interior, Natural Resource Stewardship and Science, Office of Education and Outreach, Lakewood, Colorado.

Kootznoowoo Wilderness Commercial Needs Assessment Page 16
Creek are a consequence of its history prior to wilderness designation. The viewing publics are required 

to follow strict procedures for movement and behavior that in turn provides bears an expectation and 

reduces the natural threat of people. Habituation of the bears at Pack Creek is an objective for a safe 

viewing experience for both visitors and bears. 

In addition, the Pack Creek Bear Viewing area is cooperatively managed by the Forest Service and 

Alaska Department of Fish & Game. The area is staffed on-site June through September and permits are 

required by visitors. The site has a high level of visitor controls in place for resource protection purposes. 

Untrammeled Character question:

Utc1 - Are commercial service activities compatible with preserving unhindered natural processes that are 

free from human control or manipulation?

Other Features of Value

The quality Other Features of Value pertains to distinct features fundamental to the wilderness character 

that are not contained within the other qualities:

5. Other features. This aspect is based on the last clause of Section 2c in the 1964 Wilderness Act,

that a wilderness “may also contain ecological, geological, or other features of scientific,

educational, scenic, or historical value.” This fifth quality is unique to an individual wilderness based

on the features that are inside that wilderness. These features typically occur only in specific

locations within a wilderness and include cultural resources, historical sites, paleontological sites, or

any feature not in one of the other four qualities that has scientific, educational, scenic, or historical

value. While many different types of features could be included, the intent is to include those that are

significant or integral to the park and wilderness. Features mentioned in park or wilderness enabling

legislation would likely qualify, such as the historic sites in Death Valley Wilderness and volcanoes in

Katmai Wilderness. Likewise, significant cultural sites, whether mentioned in enabling legislation or

not, occur in most wildernesses and have scientific, educational, scenic, or historical value.15

One key aspect of Kootznoowoo Wilderness is its rich cultural value as manifested in sites and 

subsistence uses intrinsic to the history and identity of its people. Both cultural sites and subsistence 

activities reflect landscape features essential to the character of Kootznoowoo Wilderness. In some cases, 

known heritage resources have been damaged or removed. Outfitters and guides may contribute to the 

protection of these resources or they may inadvertently damage them through negligence or abuse. Guides 

may also impact subsistence priorities if they bring clients in sufficient numbers to compete for limited 

subsistence resources.

Other Wilderness Character screening question:

Ovc1 - Are commercial service activities compatible with the preservation of cultural values, sites and 

subsistence activities? 

15 Landres, P., Vagias, W. & Stutzman, S. Using wilderness character to improve wilderness stewardship. Park 

Science, Volume 28, Number 3, Winter 2011-2012, ISSN 1090-9966. National Park Service, U.S. Department of 

the Interior, Natural Resource Stewardship and Science, Office of Education and Outreach, Lakewood, Colorado.

Kootznoowoo Wilderness Commercial Needs Assessment Page 17
DETERMINATION OF NEED FOR COMMERCIAL RECREATION 

SERVICE ACTIVITIES

The following section examines the commercial recreation services by activity for the Kootznoowoo 

Wilderness and finds whether or not they realize public purposes and are compatible with preserving 

wilderness character. If recreation or other public purposes are realized while wilderness character is 

upheld, commercial services may be necessary. Each activity was subjected to the public purpose and 

wilderness character screening questions. 

In order for a positive determination of need, the recreation commercial service activity must at a 

minimum meet the recreation purpose and be compatible with preserving wilderness character. Since this 

needs assessment focuses on commercial recreation services, it must at a minimum meet the recreation 

purpose as defined. Appendix 1 provides a compilation of all the screening questions and a matrix that 

displays the results of the screening questions by activity.

Remote Setting Nature Tours

Remote setting nature tour commercial service activities are necessary in the Kootznoowoo Wilderness.

Hiking, wildlife viewing, photography and sightseeing are popular activities, especially along the marine

shorelines of Kootznoowoo Wilderness. Pack Creek Bear Viewing Area is a world class opportunity that 

offers unparalleled opportunities for being with bears in their natural environment. Scenic vistas and 

wildlife observations are normally the highlights of such trips, and clients are often given opportunities to 

contemplate and appreciate nature. The experiences that result often forge deep connections to nature that 

inspire photographs and art. Guides can help clients understand the regulations and ethics surrounding the 

viewing of wildlife. Commercially guided trips sometimes involve archaeologists or historians to connect 

human habitation to the broader ecology. Hiking is a traditional pursuit that requires elements of risk and 

challenge, especially off-trail. It encourages self-reliance and helps strengthen independent decisionmaking. Hiking guides can also help preserve wilderness through avoidance of motorized equipment and 

mechanical transport, and by not competing for subsistence resources. Remote setting nature tour 

commercial service activities fulfill the public purposes and are compatible with preserving the 

wilderness character as defined by the Wilderness Act.

Floatplane Landing Tours

Floatplane landing tour commercial service activities are not necessary in the Kootznoowoo Wilderness.

Floatplanes are a common and allowed method of transport for recreation use on the Tongass NF. 

However, the authorization of floatplane landing tours on the Tongass is limited and has not been 

authorized within the Kootznoowoo Wilderness. A floatplane landing tour is defined in this assessment as 

a day-use activity that predominantly involves viewing natural features by air and landing once or 

multiple times within the wilderness and returning back to its point of origin. This activity does not 

include point-to-point floatplane services that are provided as an ancillary service to other guides who are 

permitted for other activities or for services to individuals who hire these services to provide access to 

these areas for their recreation needs; such as using a cabin, or shuttle services to and from a community. 

The determination of no need was concluded based on; 

• Failure to realize the recreational purposes for the Kootznoowoo Wilderness (Rp1-

Challenge, Rp2-Traditional);

• Failure to realize the scenic purposes for the Kootznoowoo Wilderness (Sp2-

Kootznoowoo Wilderness Commercial Needs Assessment Page 18
connections); 

• Incompatibility with preserving wilderness character per Wilderness Character Screening

Questions Oc1-Solitude and Oc2-Primitive.

This activity primarily accesses freshwater lakes within the Kootznoowoo Wilderness. The vast majority 

of freshwater lakes have developed trail access and public recreation cabins that do not require an 

extraordinary degree of specialized skill, equipment and challenge that inhibits access and enjoyment of 

the lakes by the majority of the general public (question Rp1). In addition, this activity is not considered a 

traditional wilderness pursuit within the Kootznoowoo Wilderness, as it predominantly involves viewing 

natural features from the air and landing for only short periods of time within the wilderness (question 

Rp2). Therefore, this commercial service activity is not necessary to achieve the recreation public 

purposes of the Wilderness Act. 

This activity generally does not allow opportunities for visitors to forge deep connections with nature 

uninhibited by modern civilization (question Sp2). The act of viewing the wilderness from an aircraft and 

spending relatively short periods of time on the ground, within the landscape and soundscape represents 

an activity predominantly inhibited by modern civilization (flying) and does not fulfill the scenic purposes 

of wilderness. 

Floatplane landing tours are not compatible with preserving the wilderness character of outstanding 

opportunities for solitude or a primitive and unconfined type of recreation, specifically Wilderness 

Character Screening Question Oc1 and Oc2. This activity occurring on lakes that are predominantly 

accessed by visitors from traditional wilderness means, hiking and paddling, degrades opportunities for 

those visitors to experience solitude and primitive recreation. Therefore this commercial service activity is 

not necessary due to its incompatibility with preserving outstanding opportunities for solitude or a 

primitive and unconfined type of recreation. 

Camping

Camping commercial service activities are necessary in the Kootznoowoo Wilderness. 

Outfitted and guided camping services are currently a small, but important, component of commercial use 

in the Kootznoowoo Wilderness. The majority of camping services come in connection with multiple day 

marine based kayak trips along the shoreline. Camping involves skills that embrace traditional techniques 

and require elements of risk and challenge, especially for those new to the sport. It encourages selfreliance and helps strengthen independent decision-making. Scenic vistas and wildlife observations are 

normally the highlights of such trips, and clients are often given opportunities for quiet time to 

contemplate and appreciate nature. The multiple day experiences that result often forge deep connections 

to nature that inspire photographs and art. Guides can help clients understand the regulations and ethics 

surrounding the viewing of wildlife and the requirements of camping. Outfitted and guided camping 

services may be necessary at Forest Service shelters and cabins where access is difficult and public use of 

the facilities is low.

Freshwater Fishing

Freshwater fishing commercial service activities are necessary in the Kootznoowoo Wilderness. 

Fishing guides in general can help realize the purposes of wilderness in most locations of Kootznoowoo 

Wilderness while preserving wilderness character. Historically guided fresh water fishing activities have 

largely been day-use accessed from the confluence with marine waters. Fishing is a traditional wilderness 

Kootznoowoo Wilderness Commercial Needs Assessment Page 19
pursuit where guides can teach skills and connect clients to nature in meaningful and memorable 

experiences that involve self-reliance. Fishing groups are generally smaller and they seek solitude in order 

to avoid competition with others. Fishing groups often spend more time in wilderness which enhances 

their appreciation of scenery and affords more opportunity to study nature. Guides often practice catchand-release fishing, uphold state regulations pertaining to the harvest of fish and they must report results 

to State officials who manage the harvest and consider effects upon populations. Fishing guides do not 

typically realize historical purposes of wilderness in that clients don’t study historic sites under agreement 

with archaeologists. 

Hunting

Commercial hunting activities are necessary in the Kootznoowoo Wilderness. 

Brown bear and deer guides can realize most of the public purposes while preserving wilderness 

character. Non-resident bear hunters are required under state regulation to be accompanied by a guide or 

resident family member. Kootznoowoo features accessible terrain that affords Outstanding Opportunities 

for Solitude or a Primitive and Unconfined Type of Recreation to hunters. Hunting is a traditional pursuit 

that requires ample solitude to watch, track and pursue ranging game. Skills developed during hunts often 

require challenging decision making and self-reliance. Binoculars and viewing devices are normally used 

and clients have abundant opportunities to enjoy scenery and to study nature. Guides uphold state 

regulations pertaining to the pursuit and harvest of game and they must report results to State officials 

who manage the harvest and consider effects upon populations. They have the opportunity to involve 

clients in studies and connect clients to nature through education described in their operating plans. 

Hunting guides do not help realize historical purposes of wilderness in that clients don’t study historic 

sites under agreement with archaeologists.

Kootznoowoo Wilderness Commercial Needs Assessment Page 20
APPENDIX 1: Screening questions and conclusions of screening questions 

sorted by activity

Public Purpose Screening Questions: 

Rp1 - Do the commercial service activities require an extraordinary degree of specialized skill, equipment and 

challenge that inhibits access and enjoyment by the majority of the general public? 

Rp2 - Do the commercial services align with recreation pursuits that are traditional within the Kootznoowoo 

Wilderness?

Sp1 - Do the commercial service activities enhance clients’ appreciation of the aesthetics of the wilderness? 

Sp2 - Do the commercial service activities invoke opportunities for spirituality and/or allow for deep connections 

with nature uninhibited by modern civilization?

Scp1 - Do the commercial service activities provide opportunities to assist with scientific studies or involve the 

scientific process of studying nature? 

Ep1 - Do the commercial service activities offer opportunities for education and interpretation about certain values 

of the Kootznoowoo Wilderness such as cultural, ecological or geological in a way that fosters connections to 

nature? 

Cp1 - Do the commercial service activities adhere to laws, regulations and outdoor ethics that protect and support 

wilderness character? 

Cp2 - Do the commercial service activities provide opportunities for clients to learn why certain laws, regulations 

and ethics are in place for conservation concerns?

Cp3 - Do the commercial service activities offer opportunities to engage in citizen stewardship projects and/or 

provide context to larger world conservation concerns? 

Hp1 – Do the commercial service activities offer opportunities to foster a connection between local human 

habitation and use of the wilderness and its other ecological values? 

Wilderness Character Screening Questions:

Nc1 - Are commercial service activities compatible with preserving the natural character of Kootznoowoo 

Wilderness? 

Oc1 - Are commercial services activities compatible with preserving opportunities for solitude, challenge, decisionmaking and self-reliance? 

Oc2 – Are commercial service activities compatible with preserving primitive or unconfined type of recreation 

experiences? 

Uc1 - Are commercial services activities compatible with the preserving the undeveloped character by not relying 

on developments or motorized equipment and mechanical transport not specifically allowed under ANILCA? 

Utc1 - Are commercial service activities compatible with preserving unhindered natural processes that are free from 

human control or manipulation? 

Ovc1 - Are commercial service activities compatible with the preservation of cultural values, sites and subsistence 

activities? 

Kootznoowoo Wilderness Commercial Needs Assessment Page - 21 -
Table F1-1. Wilderness Area uses, public purposes, and wilderness character. 

Remote 

Setting 

Nature 

Tours

Floatplane 

Landing 

Tours

Camping Freshwater 

Fishing Hunting

Public Purposes 

Recreational

Rp1-Challenge Yes No Yes Yes Yes

Rp2-Traditional Yes No Yes Yes Yes

Scenic

Sp1-Appreciation Yes Yes Yes Yes Yes

Sp2-Spiritual Yes No Yes Yes Yes

Scientific

Scp1-Study Yes Yes Yes Yes Yes

Educational

Ep1-Connections Yes Yes Yes Yes Yes

Conservation

Cp1-Rules/ethics Yes Yes Yes Yes Yes

Cp2-Values Yes Yes Yes Yes Yes

Cp3-Stewardship Yes Yes Yes Yes Yes

Historical

Hp1-Connections Yes Yes Yes Yes Yes

Wilderness 

Character

Natural

Nc1-Natural Yes No Yes Yes Yes

Outstanding 

Oc1-Solitude Yes No Yes Yes Yes

Oc2-Primitive Yes No Yes Yes Yes

Undeveloped

Uc1-Undeveloped Yes Yes Yes Yes Yes

Untrammeled

Utc1-

Untrammeled 

Yes Yes Yes Yes Yes

Other

Ovc1-Cultural Yes Yes Yes Yes Yes

Determination of 

Need

Yes No Yes Yes Yes

Kootznoowoo Wilderness Commercial Needs Assessment Page - 22 -
Tracy Arm – Ford’s Terror & Chuck River Wilderness 

Commercial Needs Assessment

Juneau Ranger District, Tongass National Forest

1
Executive Summary

This document applies criteria of the Wilderness Act to determine which recreation commercial service 

activities may be necessary in the Tracy Arm - Ford’s Terror and Chuck River Wilderness Areas. Section 

4(d)6 of the Wilderness Act reads: 

Commercial services may be performed within the wilderness areas designated by this Act to the 

extent necessary for activities which are proper for realizing the recreational or other wilderness 

purposes of the areas.

The preservation of wilderness character is a requirement of Sections 2(a) and 4(b) of the Wilderness Act, 

and is a critical element in determining which commercial service activities may or may not be 

compatible in these wilderness areas. There cannot be a need for commercial services that degrades 

wilderness character: preservation of wilderness character takes precedence as the paramount purpose of 

the Wilderness Act. Section 2(c) of the Wilderness Act defines wilderness and presents the terms that 

depict wilderness character.

Section 4(d)6 requires commercial services to realize purposes listed by the Wilderness Act that 

categorize beneficial uses of wilderness. These purposes, called the public purposes or recreation and 

wilderness purposes, are listed under Sections 2(c) and 4(b). Section 4(b) affirms that these purposes are 

subordinate to the primary purpose of preserving wilderness character. A positive determination of need 

for a recreation commercial service requires the activity realize public purposes while being compatible 

with preserving wilderness character. 

This assessment pertains solely to recreation commercial service activities commonly referred to as 

commercial outfitting and guiding operations. It does not consider other commercial or noncommercial 

uses. It concludes with a determination as to whether or not five categories of recreation commercial 

services are necessary in the in the Tracy Arm – Ford’s Terror and Chuck River Wilderness Areas. Need 

was determined with 17 screening questions that assessed commercial service activities against the public 

purposes and compatibility with preserving wilderness character as defined in the Wilderness Act of 1964 

and consistent with the Alaska National Interest Lands Act of 1980 (ANILCA). If recreation or other 

wilderness purposes are realized while wilderness character is upheld, commercial services may be 

deemed necessary. The following summarizes the findings:

Determination of Need for Commercial Service Activities:

• Remote setting nature tour commercial service activities are necessary in the Tracy Arm - Ford’s

Terror and Chuck River Wilderness Areas.

• Floatplane landing tour commercial service activities are not necessary in the Tracy Arm -

Ford’s Terror and Chuck River Wilderness Areas.16

• Camping commercial service activities are necessary in the Tracy Arm - Ford’s Terror and

Chuck River Wilderness Areas.

• Freshwater fishing commercial service activities are necessary in the Tracy Arm - Ford’s Terror

and Chuck River Wilderness Areas.

• Hunting commercial service activities are necessary in the Tracy Arm - Ford’s Terror and Chuck

River Wilderness Areas.

16 See p.9 for definition of floatplane landing tour.

2 
Commercial services may only occur to the extent necessary as mandated by Section 4(d)6 of the 

Wilderness Act. Subsequent site specific commercial use allocation decisions under the National 

Environmental Policy Act will further define commercial service activities (locations, timing of use, 

numbers of visitors, etc.) to ensure the preservation of wilderness character.

3 
INTRODUCTION

This document is a wilderness commercial needs assessment for the Tracy Arm - Ford’s Terror and 

Chuck River Wilderness Areas. It applies criteria of the Wilderness Act of 1964 (Wilderness Act) to 

determine which recreation commercial service activities may be necessary in the Tracy Arm – Ford’s 

Terror and Chuck River Wildernesses. 

The need for commercial services is determined by assessing the ability of activities to fulfill the 

recreational or other wilderness purposes of the Wilderness Act. In addition, commercial service activities 

must be compatible with preserving wilderness character. A determination of need may be found where 

activities fulfill public purposes of the Wilderness Act and are compatible with preserving wilderness 

character. The preservation of wilderness character will also be a critical factor in further defining sitespecific constraints in capacity allocation decisions when determining “the extent necessary” for 

commercial service activities. 

This needs assessment is part of a sequential process of administering recreation commercial use on 

National Forest System lands within wilderness. It only pertains to recreation commercial activities and 

does not apply to other commercial or non-commercial uses. Other aspects of administering recreation 

commercial use outside the scope, but tiered to this assessment include:

National Environmental Policy Act (NEPA) requires analysis of any proposed commercial 

outfitter and guide allocation of the overall recreation capacity. This analysis culminates in a 

decision that establishes mitigation measures that balance use with protection of the National 

Forest resource. The decision would define the extent and amount of commercial recreation 

use to be authorized. This process informs decision makers of choices among alternative 

courses of action based upon resource capability and public input.

A prospectus may be necessary to implement NEPA decisions when demand for 

commercially guided recreation opportunities exceeds the available capacity. A prospectus 

requires commercial operators to submit bid applications that meet specific criteria. The 

Authorized Officer allocates commercial use to businesses that best respond to the criteria.

Special uses permits authorize individual outfitter-guides within the determined allocation 

and according to established mitigation measures.

This needs assessment:

1. Determines the need for various activities of commercial outfitter-guides based on

fulfilling public purposes of the Wilderness Act and compatibility with preserving

wilderness character within the Tracy Arm - Ford’s Terror and Chuck River Wilderness

Areas.

2. Is an internal analysis.

3. Does not analyze or mitigate potential environmental impacts from commercial outfitting

and guiding activities.

4. Does not determine the extent and amount of recreation commercial use that may be

authorized.

The assessment considers the entirety of both the Tracy Arm - Ford’s Terror and Chuck River Wilderness 

Areas. 

This is intended to be a living document. It is recognized that wilderness conditions and factors that affect 

them may change, as may market demands for various commercial service activities. hen substantial 

4 
changes occur in natural systems and/or commercial recreation service markets, this assessment will be 

updated accordingly. 

This needs assessment is organized into five major sections and appendices to include:

• Introduction – provides the context and scope of this needs assessment.

• Tracy Arm - Ford’s Terror and Chuck River Wilderness Areas – provides brief overview of

the areas’ wilderness qualities and applicable laws.

• Commercial Service Activities & Public Purposes – defines the commercial service activities,

public purposes and screening questions for determining need.

• Wilderness Character – defines wilderness character and provides screening questions to

determine compatibility with activities.

• Determination of Need for Commercial Service Activities – presents findings for

determination of need

5 
TRACY ARM - FORD’S TERROR AND CHUCK RIVER WILDERNESS 

AREAS

Tracy Arm - Ford’s Terror Wilderness: A Primeval Sanctuary

Behold primordial time itself: a glacier reminding us of an ice age that began over a million years 

ago. Across the millennia this condensed ice flowed down from the mountains grinding granite 

into flour. Today, the glacier retreats as it calves icebergs into the sea and continues its 

centuries-old unveiling of the dramatic fjord it has sculpted. Ancient crumbling ice supports 

precious new life: a harbor seal pup born minutes ago flops on an iceberg. Eagles descend on the 

afterbirth and possibly the hapless pup itself. The mother seal squirms to protect her vulnerable 

newborn. Then she pushes her pup into the water and follows, their awkwardness on ice 

transformed into aquatic grace. 

The fjords of Tracy Arm and Endicott Arm comprise a primeval sanctuary where the ageless 

cycles of rock and ice and seals and eagles challenge our perceptions. Time is brief and yet 

eternal. Life is frail yet resilient. The only constant in nature is impermanence. 17 

From Human and Natural History in Tracy Arm – Ford’s Terror Wilderness:18

The Tracy Arm-Ford’s Terror Wilderness is about forty-five miles southeast of Juneau. It 

encompasses 653,179 acres of the rugged Coast Mountains bordering Holkham Bay, on the east 

side of Stephens Passage. It surrounds three dramatic glacial fjords—Tracy and Endicott Arms 

and Ford’s Terror—and extends eastward to the glaciers and high mountains of the Canadian 

border.

Tracy Arm-Ford’s Terror is mountainous and heavily glaciated, with most of its terrain above 

treeline. Although a few low valleys host mature forest, most land along shore is covered in an 

early-successional mix of alder, willow and young spruce. Steep shores, swift streams, cliffs, 

narrow gorges, glaciers and thick vegetation make travel on land difficult. The wilderness has no 

cabins or maintained trails. However, protected waters, spectacular scenery and small beaches 

contribute to ideal sea kayaking, if you can stand the rain.

For many visitors this wilderness is all about glaciers, both present and past. In addition to three 

tidewater glaciers that regularly calve ice bergs into the ocean, its surrounding mountains tell a 

dramatic story of Pleistocene glaciation, with rounded domes, sheer walls and deep, U-shaped 

valleys.

Traveling Tracy or Endicott Arms, both about thirty miles long, is like taking a trip back to the 

Pleistocene Epoch, when huge glaciers covered southeast Alaska. In Holkham Bay, where the 

arms begin, mature rain forest lines steep shores that have been de-glaciated for thousands of 

years. Permanent snowfields and a few glaciers cover mountaintops high above the bay. But 

within the fjords, the snow and ice increase and the forest is noticeably younger, a result of more 

recent glaciation. Instead of mature spruce and hemlock, thickets of alder and willow dominate the 

thin soil. A few spruce rise above the thickets, pioneers of the tall forests that will eventually fill 

the valleys. At the ends of the arms, close to the glaciers, even the alders and willows are rare. The 

developing soils only support clusters of pioneer plants such as lupine and fireweed. In this raw 

landscape, the receding glaciers uncover more bare rock and gravel each year.

The landscape also grows more dramatic within the fjords, which reach deep into the Coast 

Mountains. Some peaks exceed 7,000 feet a little more than a mile from shore. Pleistocene 

glaciers sculpted them into dramatic nunataks, horns and domes. Most still host permanent snow 

fields and alpine glaciers.

17 JRD Wilderness program specialists’ descriptive statement for the Tracy Arm - Ford’s Terror Wilderness Area. 18 By Tim Lydon, USFS wilderness ranger.

6 
Tracy Arm-Fords Terror became part of the Tongass National Forest in the early 1900s. It was 

designated a National Forest Scenic Area in 1960, after years as a tourist attraction. In 1970 it 

became a Wilderness Study Area in recognition of its dramatic beauty and opportunities for 

solitude. In 1980, it was designated wilderness as part of the Alaska National Interest Lands 

Conservation Act (ANILCA). The law put the area under the authority of the 1964 Wilderness 

Act. 

The wilderness surrounds Tracy Arm, Fords Terror and most of Endicott Arm and Holkham Bay. 

The south shore of Holkham Bay and part of Endicott Arm’s south shore are part of the adjacent 

Chuck River Wilderness, designated in 1991.

Chuck River Wilderness: The Promise of Wilderness

Chuck River reflects the rise of wilderness appreciation in modern society. The local Tlingit enjoyed the 

bounty of nature by trapping and fishing in Windham Bay. Settlers arrived in the 1890’s seeking gold. 

They dug mines into the mountains, laid roads through the forests and built structures along the shore. The 

mining boom subsided around the 1920’s, people moved on and their developments fell into disrepair. In 

the 1980’s, timber resources were marked and potential roads were staked. But before it was logged, the 

American people embraced a new value - that of wilderness. In order to protect old-growth forest and 

riparian habitat, Congress designated the Chuck River Wilderness in 1990. The section adjoining the 

Tracy Arm – Ford’s Terror Wilderness completes the protection of spectacular Endicott Arm. Today this 

wilderness patiently re-wilds its weather-beaten ruins as people treasure it for tranquility, scenic beauty, 

aged forests, healthy fish runs, hunting opportunities and protected anchorages.19 

In whole, the Tracy Arm - Ford’s Terror and Chuck River Wilderness Areas currently has at least 18 

outfitter-guide operations that offer a wide variety of activities including remote setting nature tours 

(hiking, paddling, exploring, wildlife viewing, etc.), camping, freshwater fishing, and hunting. Currently 

outfitter-guides are allowed to operate on shore along the entire marine coast of the wilderness area. Only 

one outfitter-guide, a mountain goat hunting guide, is authorized to operate within the interior lands 

(generally 1⁄2 mile or more from mean high tide) or lakes of the Tracy Arm - Ford’s Terror and Chuck 

River Wilderness Areas due to lack of market demand and appropriate environmental analysis.

The Wilderness Act and the Alaska National Interest Lands Conservation Act

The Wilderness Act authorizes Congress to designate wilderness areas amidst public lands managed by 

federal agencies. The goal of the Wilderness Act is to secure for present and future Americans the 

benefits of an enduring wilderness resource. The law achieves this goal by affirming qualities for which 

wilderness is to be administered and by limiting uses that degrade those qualities. 

The passage of ANILCA established 14 wilderness areas on the Tongass National Forest including the 

Tracy Arm - Ford’s Terror Wilderness. The Chuck River Wilderness was designated as part of an 

amendment to ANILCA passed under the Tongass Timber Reform Act of 1990. ANILCA includes 

exceptions to the Wilderness Act that apply to Alaskan wilderness areas. Specific sections that apply to 

the Tracy Arm - Ford’s Terror and Chuck River Wilderness Areas and this assessment include: 

• Section 1110(a) allows for the use of airplanes, motorboats, and snowmachines (during periods of

adequate snow).

• Section 1303(b)(3) allows for the establishment and continued use of existing administrative sites

and visitor facilities.

• Section 1307(a) allows for the continuance of visitor services that were operating on January 1,

1979 in designated conservation system areas (including the Tracy Arm - Ford’s Terror and

Chuck River Wilderness Areas); however, there are no present day commercial operations that

19 JRD Wilderness program specialists’ descriptive statement for the Chuck River Wilderness Area.

7 
were authorized use within the bounds of the Tracy Arm - Ford’s Terror and Chuck River 

Wilderness Areas on that date. 

• Section 1315(d) allows for construction of new cabins if necessary for the protection of public

health and safety.

• Section 1316 (a) allows, subject to reasonable regulation to insure compatibility, for existing uses

and future establishment, and use, of temporary campsites, tent platforms, shelters, and other

temporary facilities and equipment directly and necessarily related to taking of fish and wildlife.

• Section 1316(b) allows for the denial of the temporary facilities if the use of equipment or

facilities is determined to be detrimental to the wilderness character.

Other than the exceptions expressed in ANILCA, commercially guided uses within Tracy Arm - Ford’s 

Terror and Chuck River Wilderness Areas are administered according to the Wilderness Act of 1964 

(ANILCA Section 707). 

The principle administrative charge of the Wilderness Act is to preserve wilderness character. Agencies 

have defined wilderness character using the descriptive aspects found within the law: 

• untrammeled

• undeveloped

• natural

• outstanding opportunities for solitude or a primitive and unconfined type of recreation, and

• unique features of ecological, geological or other features of scientific, educational, scenic or

historical value.

Generally speaking, actions or uses that are compatible with these qualities may be allowed in wilderness.

The Wilderness Act also limits uses that would degrade the qualities of wilderness character. With 

specific exceptions, it prohibits commercial enterprise, permanent roads, and except as necessary to meet 

minimum requirements for the administration of the area for the purpose of this Act, temporary roads, 

motor vehicles, motorized equipment or motorboats, landing of aircraft, other forms of mechanical 

transport, or installations and structures. 

Commercial services, the subject of this needs assessment, are one of the possible exceptions to the 

prohibition on commercial enterprise per Section 4(d)6 of the Wilderness Act: 

Commercial services may be performed within the wilderness areas designated by this Act to the 

extent necessary for activities which are proper for realizing the recreational or other wilderness 

purposes of the areas. 20

20 Wilderness Act, 16 USC 1133(d)(5).

8 
COMMERCIAL SERVICE ACTIVITIES & PUBLIC PURPOSES

The Wilderness Act was redrafted sixty-five times with intense scrutiny on its wording. The deliberate 

language of Section 4(d)6 reflects this extensive editing. An examination of its specific language is 

merited. 

The following sections interpret Section 4(d)6 of the Wilderness Act and discuss how it applies to 

outfitter-guide services in the Tracy Arm - Ford’s Terror and Chuck River Wilderness Areas: 

(1) Commercial services

(2) may be performed

(3) within the wilderness areas designated by this Act

(4) to the extent necessary

(5) for activities which are proper for realizing the recreational or other wilderness purposes of

the areas.

(1) Commercial services

The Code of Federal Regulations provides guidance as to the scope of commercial services to be 

considered under Section 4(d)6 by stating that: 

The Chief, Forest Service, may permit . . . commercial services within National Forest Wilderness 

to the extent necessary for realizing the recreational or other Wilderness purposes, which include, 

but are not limited to, the public services generally offered by packers, outfitters, and guides.21

Outfitter-guide services addressed in this needs assessment include remote setting nature tours (hiking, 

paddling, skiing, wildlife viewing, photography, exploring, sightseeing, cultural tours, etc.), floatplane 

landing tours, camping, freshwater fishing, and hunting. These services represent the range of activities 

currently popular with the public who visit the Tongass National Forest. Not all of these activities are 

currently authorized within the Tracy Arm - Ford’s Terror and Chuck River Wilderness Areas, but they 

represent reasonably foreseeable future demands for services. Outfitter-guide activities that are currently 

not authorized by the Forest Service in the Tracy Arm - Ford’s Terror and Chuck River Wilderness Areas 

include skiing and floatplane landing tours.

(2) May Be Performed

The word “performed” means “to carry out or fulfill” and is accomplished by guide services under permit 

from the Forest Service. The word “may” has a specific legal meaning: “action is optional.”22 Hence the 

managing agency or authorized line officer may opt to permit or not to permit commercial services, or to 

permit some services but not others. 

(3) Within Wilderness Areas Designated By This Act

This language refers to the Wilderness Act and subsequent enabling wilderness legislation, such as 

ANILCA, which designated the Tracy Arm - Ford’s Terror Wilderness, and the TTRA which designated 

the Chuck River Wilderness as an amendment to ANILCA. 

(4) To The Extent Necessary

21 36 CFR 293.8, Permanent structures and commercial services. 22 Forest Service Manual, 1110 Directives, exhibit 1110.8.

9 
The overriding constraint on commercial services (and all types of visitor use) in wilderness is the 

mandate to preserve wilderness character. Human influences that impair wilderness character are to be 

minimized so that the natural conditions are protected, and the benefits of the wilderness resource (social, 

biological, and physical) are available to future generations. The phrase “to the extent necessary” has 

been subject to court arguments where the prevailing ruling mandates this to be a minimizing provision, 

which aligns with the overall limitations on commercialism instituted by the Wilderness Act. 

“Extent” means “scope” or “magnitude.”23 The scope or magnitude of commercial services can be 

gauged quantitatively (the number of permits issued; the number of commercial clients authorized), 

spatially (where operations are necessary or authorized) and temporally (when operations are authorized). 

Extent is further defined and constrained by the capacity or capability of the wilderness to support the 

activity without impairment to wilderness character.

Commercial service activities are “necessary” if they are found to achieve the public purposes of 

wilderness without impairment of wilderness character. 

(5) For Activities Which Are Proper for Realizing the Recreational or Other Wilderness

Purposes of the Areas

Proper activities are those that are compatible with the goals of the Wilderness Act. The paramount goal 

is the preservation of wilderness character. This includes the use and enjoyment of wilderness by present 

and future generations. Commercial services can fulfill both stewardship and service roles by engaging in 

proper and purposeful activities. 

 Activities conducted responsibly would preserve the integrity of the wilderness resource. At a minimum, 

such activities would embrace outdoor ethics to minimize impacts and avoid prohibited means that 

degrade wilderness character, excepting allowable ANILCA stipulations. The stewardship role can be 

filled further by actively educating clients regarding conservation issues and the benefits of wilderness, as 

well as by actively involving clients in citizen science projects to help administer wilderness. 

Activities enhance people’s use and enjoyment of wilderness when wilderness or recreation purposes are 

realized. Regarding the commercial service activities, this needs assessment examines five broad 

categories that encompass the spectrum of commercial outfitting and guiding operations: remote setting 

nature tours; floatplane landing tours; camping; hunting, and freshwater fishing. These activities may be 

provided if determined to be compatible with the outstanding opportunities for solitude or a primitive and 

unconfined type of recreation the Wilderness Act seeks to provide. Outfitter-guides play a meaningful 

role in teaching the skills necessary to enjoy historic and recreational pursuits, in interpreting the scenic, 

scientific, educational, conservation and historical values of the visited wilderness area and in training 

visitors to be good stewards of wilderness. 

This section concludes with examining in greater detail:

• Commercial Outfitter and Guide Service Activities

• Recreational or Other Wilderness Purposes

Commercial Outfitter and Guide Service Activities

Activities considered in this needs assessment are those that occur above mean high tide on National 

Forest System lands. Not included are strictly point-to-point transportation services that are not a tour or 

part of a package trip. Many activities that take place within the Tracy Arm - Ford’s Terror and Chuck 

River Wilderness Areas above mean high tide are done in combination with activities outside the 

wilderness on state jurisdiction submerged lands and marine waters. The activities considered in this 

needs assessment include: 1) remote setting nature tours; 2) floatplane landing tours; 3) camping; 4) 

freshwater fishing, and 5) hunting.

23 Webster’s 9th New Collegiate Dictionary, 1990, page 440.

10
Remote setting nature tours encompass, but are not limited to, a wide variety of day use activities such as 

hiking, paddling, skiing, wildlife viewing, photography, exploring, sightseeing, and cultural tours. All of 

these activities, except skiing, are popular with wilderness visitors and offered by commercial service 

providers within the Tracy Arm - Ford’s Terror and Chuck River Wilderness Areas. The size of these day 

use groups tends to be the largest of all activities (group size in wilderness is capped at a maximum of 12 

people per group). Visitors may spend from one to several hours participating in these activities. 

Desirable attributes for these activities include accessible sections of shoreline and unique features of 

geological, ecological or cultural interest. Specific areas within the Tracy Arm - Ford’s Terror and Chuck 

River Wilderness Areas that are popular for these activities include the shores near the Dawes Glacier, 

North Dawes Inlet, Sanford Cove, Wood Spit and the south shore of Holkham Bay, with other shores, 

streams and bays attracting occasional interest. Access to the wilderness and along adjacent marine 

waters is achieved by boat, aircraft or paddle craft. Travel within the wilderness is typically by foot. 

Floatplane landing tour activities are common in other parts of the Tongass National Forest, but are not 

traditional or currently authorized within the Tracy Arm - Ford’s Terror and Chuck River Wilderness 

Areas. A floatplane landing tour is defined in this assessment as a day-use activity that predominantly 

involves a substantial portion of the tour viewing natural features by air and landing once or multiple 

times within the wilderness and returning back to its point or vessel of origin. It typically involves a party 

of six to twelve people who spend little time on land and most of the time in the air flightseeing. The 

definition of a floatplane landing tour does not include point-to-point floatplane transport. 

Camping is defined as overnight use within the wilderness. Daytime activities associated with camping 

may involve boating or kayaking on marine waters or remote setting nature tours, hunting or freshwater 

fishing within the wilderness. This use depends on sites amenable to camping such as level ground, 

accessible beach, availability of water, secure boat anchorage or storage, a food cache site and so on. 

Popular camping locations feature accessible marine shoreline which can be severely limited by steepwalled fjords or sheer shorelines. This limited geographic availability combined with commonly desired 

destinations (e.g. glaciers, bays, islands) concentrates camping use in certain sites. This concentration of 

use creates impacts to the natural resource and to the areas’ outstanding opportunities for solitude. 

Camping use within the Tracy Arm - Ford’s Terror and Chuck River Wilderness Areas can be 

characterized as moderate and concentrated. It should be noted that there is significant camping use by 

noncommercial sea kayaking groups. 

Freshwater fishing includes both catch-and-take and catch-and-release methods under state sport fishing 

regulations (excludes commercial and subsistence fishing). This use depends on places and times where 

anadromous and resident fish are located. Freshwater fishing activities may be day use, or encompass 

multiple days. Anglers tend to seek out areas with more solitude and their group sizes are typically 

smaller than those of remote setting nature tour user groups. There has been almost no guided freshwater 

fishing in the Tracy Arm - Ford’s Terror Wilderness as there are much better fishing options elsewhere 

than the glacial fjords. There has been slightly more (but still little) guided freshwater fishing within the 

Chuck River Wilderness as this area has a few rivers running out of old-growth forest. 

Hunting includes the hunting of brown bear, black bear, mountain goats, deer, and waterfowl. This use 

depends on places and times where game occur and must comply with state regulations. State regulations 

require a registered guide or resident kin for nonresident big game hunters. Additionally, hunting requires 

a high degree of solitude for safety and practical reasons (undisturbed wildlife). This need for solitude 

combined with the limited number of sheltered bays / safe anchorages in the Tracy Arm – Ford’s Terror 

and Chuck River Wilderness Areas limits the number of commercial hunting guides that can operate at 

the same time without impinging on each other’s or noncommercial users’ operations. Guided hunting use 

typically reflects a boat-based guiding operation that thoroughly explores a bay, fjord or an expanded area 

of marine shoreline for the duration of the hunt. Currently there is only one outfitter-guide authorized to 

use an alpine camp as their base of operations. Groups tend to be smallest in size (average of 1.8 clients 

per group) to minimize disturbance and competition and to maximize chances of success. Hunting 

11
seasons vary by species but generally speaking are open for spring, fall and some summer months and are 

closed the during the peak of summer and for the winter. 

Recreational or Other Wilderness Purposes

Activities provided by outfitter-guides in wilderness must support the recreational or other wilderness 

purposes as defined in the Wilderness Act and enabling legislation. The “recreational or other wilderness 

purposes” clause refers to uses supported in the Wilderness Act:

Except as otherwise provided in this Act, wilderness areas shall be devoted to the public 

purposes of recreational, scenic, scientific, educational, conservation, and historical use.24

[emphasis added]

Collectively, these purposes may be referred to as the public purposes of the Wilderness Act. 

ANILCA describes similar purposes and values: 

§101. (a) In order to preserve for the benefit, use, education and inspiration of present and future

generations certain lands and waters in the State of Alaska that contain nationally significant

natural, scenic, historic, archeological, geological, scientific, wilderness, cultural, recreational, and

wildlife values, and units described in the following titles are hereby established.

These values are covered within the public purposes of the Wilderness Act examined here and within the 

wilderness character qualities examined later.

The Wilderness Act provides for certain limitations on commercial ventures. Commercial services in 

wilderness must realize the public purposes of wilderness identified in the law. Drawing a clear 

connection between commercial service activities and purposes is the basis of determining the need for 

commercial services. The Wilderness Act does not specify how many public purposes must be realized. 

Those commercial services that realize the most public purposes without impairing wilderness character 

would be the most compatible with wilderness according to the criteria of the law. 

Broadly speaking, activities provided by commercial services for realizing public purposes will expand 

the capacity of the managing federal agency to administer wilderness areas “for the use and enjoyment of 

the American people in such manner as will leave them unimpaired for future use and enjoyment as 

wilderness, and so as to provide for the protection of these areas, the preservation of their wilderness 

character, and for the gathering and dissemination of information regarding their use and enjoyment as 

wilderness....”25 Fulfillment of these purposes are further achieved by reviewing operating plans, and 

completing field inspections and/or client evaluations. More specifically, each purpose must be discussed 

individually to assure common understanding as to what realizing the purpose means. Descriptions of the 

public purposes and the screening questions for realizing them in the Tracy Arm - Ford’s Terror and 

Chuck River Wilderness Areas follow.

Recreational

The recreational use purpose of wilderness includes participation and/or instruction in traditional 

wilderness activities such as hiking, backpacking, canoeing, skiing, wildlife viewing, hunting, and fishing 

in an unconfined primitive setting that provides opportunities for solitude. There is a distinct qualitative 

aspect to the recreational purpose of wilderness: 

24 Wilderness Act, 1964, 16 USC 1133(b). 25 Wilderness Act, 1964, 16 USC 1131 (a).

12
An area of wilderness if further defined to mean in this Act an area ... which ... has outstanding 

opportunities for solitude or a primitive and unconfined type of recreation ....26 [emphasis 

added]

National Forest Wilderness resources shall be managed to promote, perpetuate, and, where 

necessary, restore the wilderness character of the land and its specific values of solitude, 

physical and mental challenge, scientific study, inspiration, and primitive recreation.27

[emphasis added]

This qualitative aspect is realized if outfitter-guides offer activities in a manner that clients can enjoy 

outstanding opportunities for solitude or primitive and unconfined recreation, including the values of 

inspiration and physical and mental challenge. 

Wilderness in Alaska can be very remote, challenging and not easily accessible to the general public. 

Specialized skills, knowledge and equipment are often required for access to recreation activities within 

Alaska wilderness areas. Outfitter-guides offer the opportunity to fulfill the recreation purposes of the 

Wilderness Act by providing services that assist in overcoming extraordinary challenge and allow the 

general public to access recreation opportunities. Aspects to consider are the technical and specialized 

needs to access wilderness and the distance from population centers. 

Recreational purpose screening questions:

Rp1 - Do the commercial service activities require a substantial degree of specialized skill, equipment and 

involve challenges that inhibit access and enjoyment by the majority of the general public? 

Rp2 - Do the commercial service activities align with traditional wilderness pursuits?

Scenic

The scenic purpose covers appreciation of the natural grandeur of the wilderness, including landscape, 

soundscape, flora and fauna. Commercial services may offer activities that support this purpose by 

allowing clients to appreciate these wild sights and sounds on their own terms. The opportunity to view 

these natural wonders often invokes a sense of inspiration within. It allows visitors to experience being a 

part of something much bigger, more complex and intangible. 

Scenic purpose screening questions:

Sp1 - Do the commercial service activities enhance clients’ appreciation of the aesthetics of the 

wilderness? 

Sp2 - Do the commercial service activities invoke opportunities for inspiration and/or allow for deep 

connections with nature uninhibited by modern civilization?

Scientific

Activities offered by commercial outfitter-guide services may be able to assist with research studying 

wildlife, vegetation, geology or other aspects of wilderness. “Citizen Science” trips embody this purpose 

well. Outfitter-guide activities might assist State Fish & Game Departments or other organizations with 

26 Wilderness Act, 1964, 16 USC 1131(c). 27 Title 36, Code of Federal Regulations, Part 293.2.

13
animal studies, either reporting field observations or providing mandatory or voluntary harvest 

information. Activities should offer clients the opportunity to be involved in scientific study to the 

greatest degree possible.

Scientific purpose screening questions:

Scp1 - Do the commercial service activities provide opportunities to assist with scientific studies or 

involve the scientific process of studying nature? 

Educational 

A key role of the outfitter-guide is to enhance client enjoyment and use of wilderness. This entails a 

teacher-student relationship that imparts knowledge and skills from the outfitter-guide to clients, and 

includes interpretation which forges emotional connections between clients and nature. 

Commercial service activities may realize the educational purpose by educating clientele about the 

purpose and value of wilderness. Tongass National Forest policy requires all wilderness commercial 

service providers to educate their clients about the history, purpose and values of the National Wilderness 

Preservation System as well as the specific wilderness area visited. 

Effective teaching occurs with the realization that wilderness offers an array of educational opportunities 

spanning the human and natural history of our country. Outfitter-guides can teach their clients skills, arts, 

history, biology, geology and other topics during wilderness excursions. Teaching occurs by connecting 

clients to nature, mentoring them and expanding their understanding and appreciation. 

Often, outfitter-guides use the art of interpretation to engage with clients about the natural wonders. 

Interpretation is more than merely providing facts such as the names, elevations and ages of distinct 

features. Interpretation seeks to forge emotional connections to nature through direct experience that 

fosters appreciation of natural systems and by encouraging people to record their appreciation through 

photos, paintings, writings or other expressions.

Educational purpose screening questions: 

 Ep1 - Do the commercial service activities offer opportunities for education and interpretation about 

certain values of the Tracy Arm - Ford’s Terror and Chuck River Wilderness Areas such as cultural, 

ecological or geological in a way that fosters connections to nature?

Conservation 

The conservation purpose may be realized from activities that provide local and global perspectives on 

conservation issues. The first ensures that activities are conducted in such a way that the wilderness 

resource remains unimpaired for present and future generations. This can be accomplished by adhering to 

laws and regulations and by practicing outdoor ethics that protect the wilderness character. Outfitter-guide 

activities should offer opportunities to not only adhere to regulations and ethics, but provide explanation 

as to why such regulations and ethics are in place. 

Examples of local conservation regulations and ethics include: state statutes that govern hunting and 

fishing in order to maintain sound populations, permit requirements that prevent overcrowding and 

resource damage, Leave No Trace practices, proper hunting and fishing ethics and proper wildlife 

viewing ethics such as marine mammal viewing guidelines.

The second means of realizing the conservation purpose is to educate clients about the valuable and 

positive role of wilderness on a planet experiencing climate change, mass extinction, biodiversity loss, 

14
habitat fragmentation, pollution and other serious plights. The Tracy Arm - Ford’s Terror Wilderness 

features some of the fastest wasting glaciers on earth; the Chuck River Wilderness features old-growth 

forest once slated for logging and re-wilded settlements. These provide opportunities to measure human 

impact on the environment and to contemplate nature’s resiliency. Outfitter-guides may offer activities 

that educate their clients as to how the values of wilderness extend beyond the immediate personal 

experience to benefit the broader world community and future generations. 

Citizen stewardship activities realize the conservation purpose to an even greater degree by participating 

in wilderness stewardship. These can range from beach clean-ups to treating invasive weeds to trail 

maintenance to monitoring solitude. There are numerous ways in which commercial service activities can 

assist agency wilderness stewardship objectives.

Conservation purpose screening questions:

 Cp1 - Do the commercial service activities adhere to outdoor ethics that protect and support wilderness 

character? 

Cp2 - Do the commercial service activities provide opportunities for clients to learn why certain laws, 

regulations and ethics are in place for conservation concerns?

Cp3 - Do the commercial service activities offer opportunities to engage in citizen stewardship projects 

and/or provide context to larger world conservation concerns?

Historical

Commercial service activities may realize the historical purpose of wilderness in two manners: by 

assisting with archeological endeavors and/or by connecting people to the human roots of an area. 

Participating in archeological endeavors should always involve authorized archeologists. It could include 

projects such as restoring a historical site or methodically inventorying and recording an area for signs 

such as pictographs or petroglyphs. It should be recognized that it is important to respect local and/or 

indigenous concerns and that it is inappropriate to publicize certain archeological sites. 

Regarding connecting people to their roots, activities can offer clients opportunities to learn about the 

human history of an area, from the indigenous peoples to explorers to settlers to contemporary locals. 

History can be taught through lectures, story-telling, books, maps and photos or local experts. 

Additionally, for those historic sites protected from disturbance which are visited by commercial 

operations, the outfitter-guides take a stewardship role to preserve the integrity of the site by protecting 

site qualities and reporting any disturbances. 

Historical screening questions: 

Hp1 – Do the commercial service activities offer opportunities to foster a connection between local 

human habitation and use of the wilderness and its other ecological values? 

15
WILDERNESS CHARACTER

In order to determine need, commercial outfitter-guide service activities must also be compatible with the 

preservation of wilderness character as defined in the Wilderness Act. This assessment describes the 

wilderness character for the Tracy Arm - Ford’s Terror and Chuck River Wilderness Areas and 

determines whether the outfitter-guide activities are compatible with their preservation for future 

generations. 

This assessment determines compatibility with the Wilderness Act and screens out inappropriate 

activities; it does not analyze the effects of outfitter-guide activities on wilderness character. That analysis 

is reserved for an environmental analysis, which will be used to define site specific constraints (i.e. 

locations, group sizes, service days, time restrictions, etc.) to further define ‘the extent necessary’ to 

preserve wilderness character.

Wilderness character is a complex idea. It considers a wide variety of qualities, local and national, 

tangible and intangible. Federal land management agencies charged with administering wilderness have 

identified five qualities that comprise wilderness character, largely taken from the Wilderness Act Section 

2(c): 

1. Natural

2. Outstanding Opportunities for Solitude or a Primitive and Unconfined Type of

Recreation

3. Undeveloped

4. Untrammeled

5. Other features of value

In order to preserve wilderness character, the characteristics and values of the individual wilderness area 

must also be further defined and sustained. The characteristics and values which articulate wilderness 

character for the Tracy Arm - Ford’s Terror and Chuck River Wilderness Areas are described in ANILCA 

Section 101(b): 

It is the intent of Congress in this Act to preserve unrivaled scenic and geological values 

associated with natural landscapes; to provide for the maintenance of sound populations of, and 

habitat for, wildlife species of inestimable value to the citizens of Alaska and the Nation, including 

those species dependent on vast relatively undeveloped areas; to preserve in their natural state 

extensive unaltered arctic tundra, boreal forest, and coastal rainforest ecosystems, to protect the 

resources related to subsistence needs; to protect and preserve historic and archeological sites, 

rivers, and lands, and to preserve wilderness resource values and related recreational opportunities 

including but not limited to hiking, canoeing, fishing, and sport hunting, within large arctic and 

subarctic wildlands and on freeflowing rivers; and to maintain opportunities for scientific research 

and undisturbed ecosystems.28

This assessment is organized to consider the wilderness character for the Tracy Arm - Ford’s Terror and 

Chuck River Wilderness Areas under each nationally defined quality. Like the previous section, each 

wilderness character quality will conclude with a screening question used to determine the need for 

commercial service activities.

Natural

The natural quality refers to the condition of the biotic and environmental elements of wilderness: 

28 The Alaska National Interest Lands Conservation Act, 1980, Section 101(b).

16
1. Natural. Wilderness ecological systems are substantially free from the effects of modern

civilization. This quality is degraded by many things, such as loss of indigenous species,

occurrence of nonindigenous species, alteration of ecological processes such as waterflow and fire

regimes, effects of climate change, loss of dark skies, and occurrence of artificial sounds. It is

preserved or improved, for example, by controlling or removing nonindigenous species or

restoring ecological processes. 29

The Tracy Arm - Ford’s Terror and Chuck River Wilderness Areas covers ecosystems from the austere 

Stikine Icefield to old growth forests. Wildlife populations range from terrestrial mammals such as black 

and brown bear, Sitka black-tailed deer, mountain goat, gray wolf and river otter to sea birds, waterfowl 

and shorebirds such as marbled and Kittzlitz murrelets, loons, scoters, oystercatchers, arctic terns and 

gulls to fish including all five salmon plus cutthroat and steelhead trout to amphibians such as boreal 

toads and various newts. Marine mammals plying the adjoining waters include humpback whales, orca, 

harbor seals, Steller sea lions and harbor porpoises. 

Key ecological processes include:

• Harbor seals returning to Tracy and Endicott Arms in the hundreds every summer to haul out in

front of the glaciers on ice floes to birth and nurse pups and to molt.

• Arctic terns returning each summer to nest in colonies in the gravelly moraines of the glaciers.

• Oystercatchers nesting on the ground and gulls nesting in cliff colonies.

• Bears feeding in the intertidal zone in late spring to get calories after the long winter and before

the vegetation returns and then feeding on salmon runs in the late summer.

There may be plant species that are officially listed as threatened and endangered in the Tracy Arm – 

Ford’s Terror wilderness areas, but none have been found yet. Invasive plants are limited to localized 

patches in areas of historic human settlement. 

Absent human influence, air quality is high. Stream water quality is believed to be high. Undeveloped 

watersheds, continuous flushing from rainfall and freezing winter temperatures contribute to purity. Soils 

range from recently de-glaciated bare rock to newly established thin soils to thick organic soils in the 

older forests.

Challenges to naturalness include:

• Tourism operations interfering with wildlife by getting too close.

• Powered vessels impairing air quality and the natural soundscape.

• Denuding of thin soil bases in recently de-glaciated areas by concentrated use.

• Climate change impacts altering ecosystems (e.g. glacial wasting; yellow cedar dying off;

warming rivers no longer supporting salmon reproduction)

Outfitter-guide services play an important role in protecting natural aspects of Tracy Arm - Ford’s Terror 

and Chuck River Wilderness Areas by respecting wildlife and by helping clients to understand wildlife 

sensitivities, game laws, and best management practices. Outfitter-guides can also help prevent the spread 

of invasive species and impacts to sensitive soils and vegetation. Outfitter-guides can also take measures 

to uphold clean air and the natural soundscape.

Natural character screening question: 

29 Landres, P., Vagias, W. & Stutzman, S. Using wilderness character to improve wilderness stewardship. Park 

Science, Volume 28, Number 3, Winter 2011-2012, ISSN 1090-9966. National Park Service, U.S. Department of 

the Interior, Natural Resource Stewardship and Science, Office of Education and Outreach, Lakewood, Colorado.

17
Nc1 - Are commercial service activities compatible with preserving the natural character of Tracy Arm - 

Ford’s Terror and Chuck River Wilderness Areas?

Outstanding Opportunities for Solitude or a Primitive and Unconfined Type of 

Recreation

As already noted under “Purposes” of Wilderness, Outstanding Opportunities for Solitude or a Primitive 

and Unconfined Type of Recreation help define wilderness character and are affected by management 

decisions in the following way:

2. Solitude or a primitive and unconfined type of recreation. Wilderness provides outstanding

opportunities for solitude or primitive and unconfined recreation. This quality is primarily about

the opportunity for people to experience wilderness, and is influenced by settings that affect this

opportunity. It is preserved or improved by management actions that reduce visitor encounters and

signs of modern civilization inside the wilderness. In contrast, this quality is degraded by agencyprovided recreation facilities, management restrictions on visitor behavior, and actions that

increase visitor encounters. 30

For the Tracy Arm - Ford’s Terror and Chuck River Wilderness Areas it is uncommon, though not rare, to 

encounter someone ashore; nonetheless, solitude has been impaired. The constrained waterways – tight 

fjords, narrow channels and intimate bays – place the off-forest marine traffic in close quarters with onforest wilderness visitors. The effect is that encounters recorded here by wilderness users are often rated 

as having more impact than similar distance encounters elsewhere. The loss of outstanding opportunities 

for solitude is a serious degradation and continuing threat facing the Tracy Arm – Ford’s Terror and 

Chuck River wilderness areas. For the first wilderness, there is a constant presence of people where 

guided recreation is growing in popularity, where engine noise carries far over water and echoes off 

granite walls, where public address announcements can be heard over three miles from the ships 

broadcasting them and where haze from emissions lingers. For the latter wilderness, the south shore of 

Holkham Bay, Sanford Cove and Windham Bay are increasingly popular anchorages for vessels offering 

commercial tours and the private lodge in Windham Bay may invite increased use. 

The wilderness staff actively monitor for conditions of solitude. These areas where this aspect of 

wilderness character has been lost or is threatened will be considered in future NEPA decision making 

processes.

Regarding Primitive and Unconfined Type of Recreation indicators, for the Tracy Arm – Chuck River 

wilderness areas there has been little change in recent years. There are no cabins, shelters or outhouses in 

the wilderness areas. The single trail up from Windham Bay to Taylor Lake has been buried under a 

massive landslide and flooded by diligent beavers; there is no intention of re-creating it. Two food-storage 

cables have been fixed in Ford’s Terror in areas popular with campers and bears, but lacking in trees 

adequate for caching food. Primitive and Unconfined Recreation Opportunities abound. 

Outfitter-guide activities can enhance the wilderness experience quality for visitors, contributing to 

people’s use and enjoyment of wilderness, and mitigate visitor impacts leaving such outstanding 

opportunities unimpaired. Where commercial service activities occur often, in numbers, or with a large 

footprint (spread out, loud noise, bright lights, lingering exhaust), the outstanding opportunities for 

solitude or a primitive and unconfined type of recreation quality suffers. A recent threat analysis prepared 

for Tracy Arm - Ford’s Terror and Chuck River Wilderness Areas noted, 

30 Landres, P., Vagias, W. & Stutzman, S. Using wilderness character to improve wilderness stewardship. Park 

Science, Volume 28, Number 3, Winter 2011-2012, ISSN 1090-9966. National Park Service, U.S. Department of 

the Interior, Natural Resource Stewardship and Science, Office of Education and Outreach, Lakewood, Colorado.

18
Activities authorized under special use permit, as well as those occurring adjacent to wilderness on 

the marine waters or inholdings, add more visiting parties to the landscape. Increased visitor 

presence and the haze produced by cruise vessels affect the outstanding opportunities for 

solitude or primitive and unconfined recreation.31 

Outstanding opportunities for solitude or a primitive and unconfined type of recreation 

character screening questions: 

Oc1 - Are commercial services activities compatible with preserving opportunities for solitude, challenge, 

decision-making and self-reliance? 

Oc2 – Are commercial service activities compatible with preserving primitive or unconfined type of 

recreation experiences?

Undeveloped

The undeveloped quality is essential to primeval wilderness which contrasts with those areas where 

expanding settlement and growing mechanization have occupied and modified the land: 

3. Undeveloped. Wilderness retains its primeval character and influence and is essentially without

permanent improvement or modern human occupation. This quality is influenced by what are

commonly called the “Section 4c prohibited uses,” that is, the presence of modern structures,

installations, habitations, and use of motor vehicles, motorized equipment, or mechanical

transport. The removal of structures and not conducting these prohibited uses preserve or improve

this quality. In contrast, the presence of structures and prohibited uses degrades this quality,

whether by the agency for administrative purposes, by others authorized by the agency, or when

there are unauthorized uses. 32

ANILCA specifically allowed for the continued use of airplanes, motorboats, and snowmachines (during 

periods of adequate snow cover) for traditional activities and travel to and from villages and homesites. 

These ANILCA exceptions do not alone constitute a degradation of the Undeveloped Quality.33 

Indicators for the Undeveloped Quality relate to the presence/absence of constructs and uses reflecting 

modern development rather than primeval wilderness. In terms of structures and installations on national 

forest system land, the Tracy Arm – Ford’s Terror and Chuck River wilderness areas are largely 

undeveloped save for ANILCA-allowed navigational aids and scattered USGS survey markers.34 The 

Beezer Mountain radio repeater lies just outside the wilderness boundary and the communication site on 

Dry Mountain is also outside of wilderness. 

Regarding inholdings, there are a few areas of non-national forest land in the Tracy Arm – Ford’s Terror 

wilderness area that could potentially be developed to the detriment of the wilderness character. The 

Chuck River wilderness area has several developed inholdings, including a waterfront lodge. The Forest 

Service has acquired some inholdings from willing sellers; however new owners with strong tourism 

31 Tracy Arm - Ford’s Terror and Chuck River Wilderness Areas Information Needs Assessment, 2011. 32 Landres, P., Vagias, W. & Stutzman, S. Using wilderness character to improve wilderness stewardship. Park 

Science, Volume 28, Number 3, Winter 2011-2012, ISSN 1090-9966. National Park Service, U.S. Department of 

the Interior, Natural Resource Stewardship and Science, Office of Education and Outreach, Lakewood, Colorado.

33 Note, however, that noise, lights and emissions from such modes of transportation may degrade outstanding 

opportunities for solitude. Lower profile vehicles are more conducive to preserving wilderness character in this 

regard. This is not much different than noting that while people may visit wilderness, at a certain magnitude (of 

numbers or concentration), crowdedness degrades solitude.

34 Recreational structures and installations are considered under Outstanding Opportunities for Solitude or a

Primitive and Unconfined Type of Recreation.

19
industry connections have recently purchased the lodge. Renovation and new construction could further 

impair the Undeveloped Quality of the surrounding area (and associated use and effects might comprise 

additional impacts, as well as afford new opportunities to realize educational, recreational and 

experiential benefits).

Undeveloped character screening question: 

Uc1 - Are commercial services activities compatible with the preserving the undeveloped character by not 

relying on developments or motorized equipment and mechanical transport not specifically allowed under 

ANILCA?

Untrammeled

“Untrammeled” is also defined as “unfettered”:

4. Untrammeled. Wilderness is essentially unhindered and free from the actions of modern

human control or manipulation. This quality is influenced by any activity or action that controls or

manipulates the components or processes of ecological systems inside the wilderness.

Management actions that are not taken support or preserve the untrammeled quality, while actions

that are taken degrade this quality, even when these actions are taken to protect resources, such as

spraying herbicides to eradicate or control nonindigenous species or reducing fuels accumulated

from decades of fire exclusion. 35

ANILCA allows a few exceptions for actions that may impair the untrammeled wilderness character 

quality, such as fish habitat enhancement. 

Regarding the Tracy Arm – Ford’s Terror and Chuck River wilderness areas, outfitter-guides generally do 

not intentionally control or manipulate ecological systems or their constituents. Commercial operators 

may affect wildlife, vegetation, air quality and other natural aspects, but these impacts are considered 

under the natural quality of wilderness character. 

Some commercial operators have expressed interest in assisting in USFS-led weed pulls to eradicate 

invasive weeds. Such instances would impinge the untrammeled quality, but likely be offset by the 

positive benefits to naturalness and the realization of conservation and education purposes.

Untrammeled Character question: 

Utc1 - Are commercial service activities compatible with preserving unhindered natural processes that are 

free from human control or manipulation? 

Other Features of Value

The quality Other Features of Value pertains to distinct features fundamental to the wilderness character 

that are not contained within the other qualities:

5. Other features. This aspect is based on the last clause of Section 2c in the 1964 Wilderness

Act, that a wilderness “may also contain ecological, geological, or other features of scientific,

educational, scenic, or historical value.” This fifth quality is unique to an individual wilderness

based on the features that are inside that wilderness. These features typically occur only in specific

locations within a wilderness and include cultural resources, historical sites, paleontological sites,

or any feature not in one of the other four qualities that has scientific, educational, scenic, or

historical value. While many different types of features could be included, the intent is to include

35 Landres, P., Vagias, W. & Stutzman, S. Using wilderness character to improve wilderness stewardship. Park 

Science, Volume 28, Number 3, Winter 2011-2012, ISSN 1090-9966. National Park Service, U.S. Department of 

the Interior, Natural Resource Stewardship and Science, Office of Education and Outreach, Lakewood, Colorado.

20
those that are significant or integral to the park and wilderness. Features mentioned in park or 

wilderness enabling legislation would likely qualify, such as the historic sites in Death Valley 

Wilderness and volcanoes in Katmai Wilderness. Likewise, significant cultural sites, whether 

mentioned in enabling legislation or not, occur in most wildernesses and have scientific, 

educational, scenic, or historical value.36

The history of Tracy Arm – Ford’s Terror and Chuck River Wildernesses includes cultural sites and 

subsistence uses intrinsic to the history and identity of its people. Former settlement sites related to native 

Alaskans, miners and fox farmers have been identified in the Tracy Arm – Ford’s Terror and Chuck River 

Wildernesses – and large areas still remain uninventoried by archeologists. Subsistence opportunities 

exist for seal, mountain goat, bear, deer, smaller fur-bearers, salmon, berries and other resources. 

Professional outfitter-guides and properly managed commercial services may help protect cultural sites 

and artifacts and uphold subsistence opportunities. Conversely, improperly managed or conducted 

commercial operations may damage such sites or artifacts through negligence or abuse. Guides may also 

impact subsistence opportunities if their operations result in:

• Reduction in resources available for subsistence

• Major redistribution of resources

• Substantial interference with access to resources

• Major increases in the use of subsistence resources by nonrural residents37

Commercial services should only occur if they are compatible with upholding these Other Features of 

Value for the Tracy Arm – Ford’s Terror and Chuck River Wilderness Areas.

Other Wilderness Character screening question: 

Ovc1 - Are commercial service activities compatible with the preservation of cultural values, sites and 

subsistence?

Ovc2 – Are commercial service activities compatible with the preservation of prominent ecological, 

geological and scenic features identified in the Tracy Arm – Ford’s Terror and Chuck River Wilderness 

Areas?

36 Landres, P., Vagias, W. & Stutzman, S. Using wilderness character to improve wilderness stewardship. Park 

Science, Volume 28, Number 3, Winter 2011-2012, ISSN 1090-9966. National Park Service, U.S. Department of 

the Interior, Natural Resource Stewardship and Science, Office of Education and Outreach, Lakewood, Colorado.

37 Region 10 Amendment 2090.23-2006-1, 2006, Forest Service Handbook 2090.23, Chapter Zero Code, page 5.

21
DETERMINATION OF NEED FOR COMMERCIAL SERVICE ACTIVITIES

The following section examines the commercial services by activity for the Tracy Arm - Ford’s Terror 

and Chuck River Wilderness Areas. Each activity was subjected to the public purpose and wilderness 

character screening questions. In order for a positive determination of need, the recreation commercial 

service activity must realize recreation or other wilderness purposes and be compatible with preserving 

wilderness character. Appendix 1 provides a compilation of all the screening questions and a matrix that 

displays the results of the screening questions by activity. 

Remote Setting Nature Tours

Remote setting nature tour commercial service activities are necessary in the Tracy Arm - Ford’s Terror 

and Chuck River Wilderness Areas.

Hiking, wildlife viewing, photography and sightseeing are popular activities, especially along the marine 

shorelines of Tracy Arm - Ford’s Terror and Chuck River Wilderness Areas. The glacial fjords offer 

world class opportunities to witness tidewater glaciers, sculpted fjords and how life succeeds an ice age. 

Scenic vistas and wildlife observations are normally the highlights of such trips, and clients are often 

given opportunities to contemplate and appreciate nature. The experiences that result often forge deep 

connections to nature that inspire photographs and art. Guides can help clients understand the regulations 

and ethics surrounding the viewing of wildlife. Commercially guided trips sometimes involve 

archaeologists or historians to connect human habitation to the broader ecology. Hiking is a traditional 

pursuit that requires elements of risk and challenge, especially off-trail. It encourages self-reliance and 

helps strengthen independent decision-making. Hiking guides can also help preserve wilderness through 

avoidance of motorized equipment and mechanical transport, and by not competing for subsistence 

resources. Remote setting nature tour commercial service activities fulfill the public purposes and are 

compatible with preserving the wilderness character as defined by the Wilderness Act.

Floatplane Landing Tours

Floatplane landing tour commercial service activities are not necessary in the Tracy Arm - Ford’s Terror 

and Chuck River Wilderness Areas.

Floatplane landing tour activities are common in other parts of the Tongass National Forest, but are not 

traditional or currently authorized within the Tracy Arm - Ford’s Terror and Chuck River Wilderness 

Areas. A floatplane landing tour is defined in this assessment as a day-use activity that predominantly 

involves viewing natural features by air and landing once or multiple times within the wilderness. The 

definition of floatplane landing tours does not include point-to-point floatplane services that are provided 

as an ancillary service to other guides who are permitted for other activities or for services to individuals 

who hire these services to provide access to these areas for their recreation needs, such as using a cabin, 

or shuttle services to and from a community.

The determination of no need was concluded based on Public Purpose Screening Questions Rp2-

Traditional, Sp2-Inspirational and Cp3-Stewardship; and Wilderness Character Screening Questions Nc1-

Natural, Oc1-Solitude and Oc2-Primitive. Compared to other activities examined in this assessment, 

floatplane landing tours realize fewer public purposes and degrade wilderness character.

This activity primarily accesses freshwater lakes or marine waters. There are few suitable lakes within the 

Tracy Arm - Ford’s Terror and Chuck River Wilderness Areas and they afford outstanding opportunities 

22
for solitude that have been lost along the accessible marine corridors penetrating the wilderness. There is 

no need to introduce floatplane landing tours along the well-trafficked marine waters to access sites 

already used by boat-based tourism. In addition, this activity is not considered a traditional wilderness 

pursuit, as it predominantly involves viewing natural features from the air and landing for only short 

periods of time within the wilderness (question Rp2). This activity generally does not allow opportunities 

for visitors to forge deep connections with nature uninhibited by modern civilization. The act of viewing 

the wilderness from an aircraft and spending relatively short periods of time on the ground, within the 

landscape and soundscape represents an activity dominated by modern mechanization and convenience 

(flying) and does not fulfill the scenic purposes of wilderness (question Sp2). This activity, with brief 

visits in wilderness but primarily focused on flying, does not offer an in-depth experience that supports 

participation in citizen stewardship projects; nor does it provide sufficient context for larger world 

conservation concerns (question Cp3). Therefore, this commercial service activity is not necessary to 

achieve the recreation public purposes of the Wilderness Act. 

Floatplane landing tours are not compatible with preserving wilderness character, in particular, with 

regards to naturalness and to outstanding opportunities for solitude or a primitive and unconfined type of 

recreation, specifically Wilderness Character Screening Questions Nc1, Oc1 and Oc2. The confined 

fjords with granite walls and marine floors project aircraft noise for many miles. This activity would 

occur on lakes that afford degrees of solitude rare elsewhere in the wilderness and would degrade 

opportunities for those visitors to experience solitude and primitive recreation. Therefore this commercial 

service activity is not necessary due to its incompatibility with preserving outstanding opportunities for 

solitude or a primitive and unconfined type of recreation. 

Camping 

Camping commercial service activities are necessary in the Tracy Arm - Ford’s Terror and Chuck River 

Wilderness Areas.

Outfitted and guided camping services are currently a small component of commercial use in the Tracy 

Arm - Ford’s Terror and Chuck River Wilderness Areas, but significant in the rich experiences they 

afford visitors. The majority of camping services occur in connection with multiple day marine based 

kayak trips along the shoreline. Camping involve skills that embrace traditional techniques and require 

elements of risk and challenge, especially for those new to the activity. It encourages self-reliance and 

helps strengthen independent decision-making. Scenic vistas and wildlife observations are normally the 

highlights of such trips, and clients are often given opportunities for quiet time to contemplate and 

appreciate nature. The multiple day experiences that result often forge deep connections to nature that 

inspire photographs and art. Guides can help clients understand the regulations and ethics surrounding the 

viewing of wildlife and the requirements of camping.

Freshwater Fishing

Freshwater fishing commercial service activities are necessary in the Tracy Arm - Ford’s Terror and 

Chuck River Wilderness Areas. 

Fishing guides in general can help realize the purposes of wilderness in most locations of Tracy Arm - 

Ford’s Terror and Chuck River Wilderness Areas while preserving wilderness character. Historically 

guided fresh water fishing activities have largely been day-use accessed from the confluence with marine 

waters. Fishing is a traditional wilderness pursuit where guides can teach skills and connect clients to 

nature in meaningful and memorable experiences that involve self-reliance. Fishing groups are generally 

23
smaller and they seek solitude in order to avoid competition with others. Fishing groups often spend more 

time in wilderness which enhances their appreciation of scenery and affords more opportunity to study 

nature. Guides often practice catch-and-release fishing, uphold state regulations pertaining to the harvest 

of fish and report results to State officials who manage the harvest and consider effects upon populations. 

Fishing guides do not typically realize historical purposes of wilderness in that clients don’t study historic 

sites under agreement with archaeologists. 

Hunting

Commercial hunting activities are necessary in the Tracy Arm - Ford’s Terror and Chuck River 

Wilderness Areas. 

Hunting guides can realize most of the public purposes while preserving wilderness character. Nonresident big game hunters are required under state regulation to be accompanied by a guide or resident 

family member. The Tracy Arm – Ford’s Terror and Chuck River Wildernesses feature accessible terrain 

that affords Outstanding Opportunities for Solitude or a Primitive and Unconfined Type of Recreation to 

hunters. Hunting is a traditional pursuit that requires ample solitude to watch, track and pursue ranging 

game. Skills developed during hunts often require challenging decision making and self-reliance. 

Binoculars and viewing devices are normally used and clients have abundant opportunities to enjoy 

scenery and to study nature. Guides uphold state regulations pertaining to the pursuit and harvest of game 

and they must report results to State officials who manage the harvest and consider effects upon 

populations. They have the opportunity to involve clients in studies and connect clients to nature through 

education described in their operating plans. Hunting guides do not help realize historical purposes of 

wilderness in that clients don’t study historic sites under agreement with archaeologists.

24
APPENDIX 1: Screening questions and conclusions of screening questions 

sorted by activity

Public Purpose Screening Questions: 

Rp1 - Do the commercial service activities require an extraordinary degree of specialized skill, equipment and 

involve challenges that inhibit access and enjoyment by the majority of the general public? 

Rp2 - Do the commercial service activities align with traditional wilderness pursuits? 

Sp1 - Do the commercial service activities enhance clients’ appreciation of the aesthetics of the wilderness? 

Sp2 - Do the commercial service activities invoke opportunities for inspiration and/or allow for deep connections 

with nature uninhibited by modern civilization?

Scp1 - Do the commercial service activities provide opportunities to assist with scientific studies or involve the 

scientific process of studying nature? 

Ep1 - Do the commercial service activities offer opportunities for education and interpretation about certain values 

of the Tracy Arm - Ford’s Terror and Chuck River Wilderness Areas such as cultural, ecological or geological in a 

way that fosters connections to nature?

Cp1 - Do the commercial service activities adhere to laws, regulations and outdoor ethics that protect and support 

wilderness character? 

Cp2 - Do the commercial service activities provide opportunities for clients to learn why certain laws, regulations 

and ethics are in place for conservation concerns?

Cp3 - Do the commercial service activities offer opportunities to engage in citizen stewardship projects and/or 

provide context to larger world conservation concerns?

Hp1 – Do the commercial service activities offer opportunities to foster a connection between local human 

habitation and use of the wilderness and its other ecological values?

Wilderness Character Screening Questions:

Nc1 - Are commercial service activities compatible with preserving the natural character of Tracy Arm - Ford’s 

Terror and Chuck River Wilderness Areas?

Oc1 - Are commercial services activities compatible with preserving opportunities for solitude, challenge, decisionmaking and self-reliance? 

Oc2 – Are commercial service activities compatible with preserving primitive or unconfined type of recreation 

experiences?

Uc1 - Are commercial services activities compatible with the preserving the undeveloped character by not relying 

on developments or motorized equipment and mechanical transport not specifically allowed under ANILCA?

Utc1 - Are commercial service activities compatible with preserving unhindered natural processes that are free from 

human control or manipulation? 

Ovc1 - Are commercial service activities compatible with the preservation of cultural values, sites and subsistence 

activities?

Ovc2 – Are commercial service activities compatible with the preservation of prominent ecological, geological and 

scenic features identified in the Tracy Arm – Ford’s Terror and Chuck River Wilderness Areas?

25
Table F2-1. Findings for the Tracy Arm – Ford’s Terror and Chuck River Wilderness Areas

Remote 

Setting Nature 

Tours

Floatplane

Landing Tours Camping Freshwater 

Fishing Hunting

Public Purposes 

Recreational

Rp1-Challenge Yes No Yes Yes Yes

Rp2-Traditional Yes No Yes Yes Yes

Scenic

Sp1-Appreciation Yes Yes Yes Yes Yes

Sp2-Inspirational Yes No Yes Yes Yes

Scientific

Scp1-Study Yes Yes Yes Yes Yes

Educational

Ep1-Connections Yes Yes Yes Yes Yes

Conservation

Cp1-Rules/ethics Yes Yes Yes Yes Yes

Cp2-Values Yes Yes Yes Yes Yes

Cp3-Stewardship Yes No Yes Yes Yes

Historical

Hp1-Connections Yes Yes Yes Yes Yes

Wilderness Character

Natural

Nc1-Natural Yes No Yes Yes Yes

Outstanding 

Oc1-Solitude Yes No Yes Yes Yes

Oc2-Primitive Yes No Yes Yes Yes

Undeveloped

Uc1-Undeveloped Yes Yes Yes Yes Yes

Untrammeled

Utc1-Untrammeled Yes Yes Yes Yes Yes

Other

Ovc1-Cultural Yes Yes Yes Yes Yes

Ovc2-OtherFeatures Yes Yes Yes Yes Yes

Determination of Need Yes No Yes Yes Yes

26
Determination of Need for Commercial Services in the 

Pleasant/Lemesurier/Inian Islands Wilderness Area

Hoonah Ranger District, Tongass National Forest

- 1 - 
Table of Contents 

I. Introduction..................................................................................................................................................................... - 3 -

II. Wilderness Management Direction.................................................................................................................. - 3 -

III. Pleasant/Lemesurier/Inian Islands (PLI) Wilderness ........................................................................... - 4 -

Area Description........................................................................................................................................................ - 4 -

Statement Defining the Wilderness Character of the PLI Wilderness Area...................................... - 4 -

Existing Condition - Commercial Visitor Use ................................................................................................ - 5 -

IV. Evaluation Process for Determination of Public Need............................................................................ - 7 -

V. Evaluation of Activities Authorized for PLI Wilderness Area............................................................... - 8 -

VI. Determination of Need for Commercial Services ................................................................................... - 11 -

Special Uses Management Direction.............................................................................................................. - 11 -

Recreation Opportunity Spectrum (ROS).................................................................................................... - 11 -

Assumptions and Evaluation Criteria............................................................................................................ - 11 -

VII. Determination of Need for Commercial Services by Activity ......................................................... - 14 -

Activities Considered............................................................................................................................................ - 14 -

Remote Setting Nature Tours ........................................................................................................................... - 14 -

Camping..................................................................................................................................................................... - 16 -

Freshwater Fishing ............................................................................................................................................... - 17 -

Big Game Hunting.................................................................................................................................................. - 18 -

VIII. Summary.............................................................................................................................................................. - 19 -

Decision...................................................................................................................................................................... - 19 -

Appendix 1. Wilderness Management Direction.......................................................................................... - 20 -

The Wilderness Act of 1964 .............................................................................................................................. - 20 -

Alaska National Interest Lands Conservation Act of 1980 (ANILCA).............................................. - 20 -

Direction Provided by Regulation................................................................................................................... - 21 -

Agency Direction.................................................................................................................................................... - 21 -

Forest Plan Direction for Wilderness (pages 3-7 to 3-25).................................................................... - 24 -

Appendix 2. Special Use Permit Stipulations for Outfitting and Guiding on National Forest System 

Lands, Tongass National Forest........................................................................................................................... - 26 -

Appendix 3. ROS Classes for PLI Wilderness (Tongass Land and Resource Management Plan 

2008 ).............................................................................................................................................................................. - 28 -

Semi-Primitive Non-Motorized........................................................................................................................ - 28 -

Semi-Primitive Motorized.................................................................................................................................. - 29 -

- 2 - 
I. Introduction

The Hoonah Ranger District (HRD) has developed this needs assessment to determine the types of 

commercial outfitter and guide activities that could take place in the Pleasant / Lemesurier / Inian Islands 

(PLI) Wilderness. A needs assessment is a methodology for determining if, in fact, there is a ‘need’ for 

private enterprise to assist the agency in providing access, services and/or other assistance for the 

recreating public to safely and properly enjoy National Forest wilderness areas. This document is tiered to 

the 2008 Tongass Land and Resource Management Plan (Forest Plan) and the Determination of Need and 

Extent of Commercial Uses within Wilderness Areas on the Tongass National Forest (USDA 2007). 

As identified in The Wilderness Act of 1964: “Commercial services may be performed with the 

wilderness areas designated by this Act to the extent necessary for activities which are proper for realizing 

the recreational or other wilderness purposes of the areas”.

Public need is identified by the Forest Service for activities that are deemed essential or required for the 

well-being of the public and in order to meet the intent of the Forest Service’s mission to manage and 

protect resources, provide for public safety, and provide high-quality public recreation services. Marketgenerated demand for conducting outfitting and guiding activities does not, by itself, constitute a need for 

commercial services. Identification of need also considers how an outfitter and guide operation can 

contribute to meeting Forest Plan management objectives. 

Outfitters and guides can serve as important partners for the Forest Service. In particular, guides provide 

wilderness awareness and leave no trace education. Outfitters and guides can also assist with monitoring 

activities, such as reporting invasive plants and illegal activities, which help the Forest Service achieve a 

higher level of wilderness stewardship. For visitors who might not otherwise be exposed through typical 

education and outreach efforts, outfitters and guides can help build support for Wilderness preservation. 

A commercial needs assessment is not a decision document subject to environmental analysis. Rather, it 

is an analytical tool. A separate analysis, known as a visitor capacity, will be done in conjunction with 

this needs assessment to identify the recreational capacity (for both guided and unguided use) of the PLI 

Wilderness. The decision to allocate a portion of the visitor capacity to outfitted and guided visitors, as 

well as the decision to issue or renew outfitter and guide permits, will be accomplished through an 

environmental analysis in compliance with the National Environmental Policy Act (NEPA). 

Existing outfitter and guide activities occurring in the PLI Wilderness are authorized under the Shoreline 

Outfitter/Guide Record of Decision (ROD) and Final Environmental Impact Statement (FEIS; 2004). This 

decision is currently under review. 

II. Wilderness Management Direction

This document includes excerpts for wilderness management from the following resources (see Appendix 

1): 

• The Wilderness Act of 1964

• Alaska National Interest Lands Conservation Act of 1980 (ANILCA)

• Title 36 - Code of Federal Regulations

• USDA Forest Service Strategic Plan FY 2007-2012

• Forest Service Chief’s 10-Year Wilderness Stewardship Challenge

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• Forest Service Manual 2320, Wilderness Management

• Tongass National Forest, Land and Resource Management Plan, 2008 (Forest Plan)

• Recreation Opportunity Spectrum (ROS)

• Forest Service Special Use Permit Stipulations for Outfitting and Guiding on National Forest

System lands, Tongass National Forest, 2012.

III. Pleasant/Lemesurier/Inian Islands (PLI) Wilderness

Area Description

In 1990 Congress designated 23,096 acres located north of Hoonah as the Pleasant/Lemesurier/Inian 

Islands Wilderness. These scenic islands are located along the Icy Strait corridor near the entrance to 

Glacier Bay National Park and Preserve, north of the City of Hoonah. 

Pleasant Island, the easternmost island, lies fairly flat with dense forest and vast muskegs; its highest 

point, The Knob, is at approximately 600 feet. At least two of the island's lakes and three of its streams 

hold fresh water. It is about two miles from the City of Gustavus across Icy Passage and accessible by 

boat. Residents hunt and gather with success here. 

Lemesurier Island, the next island west is mostly rolling terrain with one peak reaching 2,180 feet above 

sea level--high enough to claim sub-alpine habitat. It is densely forested with several freshwater streams 

and small lakes. Hoonah Ranger District maintains a primitive trail that leads to a lake above Jacks Cove. 

This lake has no outlet and is surrounded by carbonate bedrock, which suggests a viable karst system. 

There are two parcels of private land on this island. 

The Inian Islands, westernmost of this Wilderness are made up of four main islands with four smaller 

satellites. A short distance north off the Inian Peninsula and the community of Elfin Cove, the “Inians” 

rise to about 1,000 feet on the largest island. Substantial tree cover provides habitat for deer and small 

mammals. 

Statement Defining the Wilderness Character of the PLI Wilderness Area

The Wilderness Act of 1964 directs “each agency administering any area designated as Wilderness shall 

be responsible for preserving the Wilderness character of the area.” Section 2(c) of the Act defines four 

qualities of Wilderness that managers try to preserve. These qualities as they relate to PLI Wilderness 

include: 

• Untrammeled – The Wilderness is essentially unhindered and free from modern human control or

manipulation. The existing outfitter/guide activities for Remote Setting Nature Tours and Camping

have not developed significant impacts and have not altered natural systems in the PLI Wilderness

area.

• Natural - Wilderness ecological and evolutionary systems are substantially free from the effects of

modern civilization. The current outfitting/guiding activities do not manipulate vegetation, soils, air

quality, or other physical and biological components of this wilderness.

• Undeveloped - Wilderness retains its primeval character and influence and has minimal evidence

of modern human occupation or modification. The existing outfitter/guide activities do not

establish permanent structures and guides practice Leave-No-Trace principles.

• Outstanding opportunities for solitude or a primitive and unconfined type of recreation Wilderness

provides outstanding opportunities for people to experience natural sights and sounds, solitude,

freedom, risk, and the physical and emotional challenges of self-discovery and self-reliance. The

PLI Wilderness area is located along the Icy Strait corridor between the communities of Hoonah,

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Gustavus, and Elfin Cove. This corridor receives continuous boat and plane traffic. Once ashore, 

these wilderness islands are relatively free of human encounters and guided hiking and camping 

activities expose clients to outstanding opportunities for a primitive recreation experience. 

Existing Condition - Commercial Visitor Use

Like many of the wilderness areas in Alaska, PLI Wilderness is only accessible by float plane or boat. 

There is no single departure or access point for this Wilderness area. Current recreation use consists of 

hunting, visiting the shoreline beaches, hiking, and camping. Boaters skirt the islands traveling between 

the communities of Juneau, Hoonah, Gustavus, Elfin Cove, and Pelican. Much of the use in PLI 

Wilderness consists of visitors from fishing boats and pleasure crafts stopping on accessible beaches 

when weather permits. 

Commercial outfitters and guides are permitted to use the PLI Wilderness and their activities provide 

services for forest visitors that are unfamiliar with Southeast Alaska’s wilderness. Outfitters and guides 

are required to submit use reports annually that identify the use location, type of use, number of clients, 

number of groups, and length of stay at each location. From this information, the number of service days 

used at each location is calculated. A service day is defined as a day, or any part of a day, on National 

Forest System lands for which an outfitter or guide provides goods or services, including transportation, 

to a client. Actual use reports provide an effective mechanism to track and monitor outfitter and guide use 

in wilderness. 

Currently the Hoonah Ranger District has no means to track the number of private users that recreate in 

this wilderness area. 

A review of the past and current outfitter/guide use, as well as the potential of additional use, was used as 

a foundation for this needs assessment. Based on past and potential future use, the following 

outfitter/guide activities were considered for this needs assessment: 

• Remote Setting Nature Tours

• Camping

• Freshwater Fishing

• Big Game Hunting

Table 3-1 shows the permitted outfitter/guide use activities and actual use that occurred on PLI 

Wilderness between 2007 to 2012. 

Table F3-1. Authorized Outfitter/Guide Activities and Actual Use -- PLI Wilderness (2007-

2012).

Actual Use – Service Days

Activity 2007 2008 2009 2010 2011 201

2 

TOTAL

Remote Setting Nature Tours 174 158 78 91 124 207 832

Camping 0 0 0 10 0 0 10

Freshwater Fishing 0 0 0 0 0 0 0 

Big Game Hunting 0 0 0 0 0 0 0 

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TOTAL 174 158 78 105 124 207 842

1 A service day is defined as a day, or any part of a day, on National Forest System lands for 

which an outfitter or guide provides goods or services, including transportation, to a client.

The Pleasant/Lemesurier/Inian Islands Wilderness area is split between Guide Use Area (GUA) 04-11 

and 04-16. GUA 04-11 includes Pleasant Island. GUA 04-16 is split into four sub-units – 04-16A, 04-

16B, 04-16C, and 04-16D. GUA 04-16D includes Lemesurier and Inian Islands. 

Authorizations for big game hunting and freshwater fishing activities are generally permitted for 

individual Guide Use Areas (GUA). Each GUA may include a portion of designated wilderness. 

Although big game hunters and fishing guides may be permitted to operate in a particular GUA that may 

include a portion of a wilderness area, these activities take place where fish and game are more likely to 

occur. 

No big game hunting or freshwater fishing activities have taken place on PLI Wilderness in the last five 

years. There are no anadromous fish streams on the islands and brown bear do not inhabit the islands. 

Though there may be an occasional transient brown bear on the islands that make up PLI Wilderness, 

there is an extremely low likelihood of conducting a viable hunt for brown bear within the Wilderness. 

Successful brown bear hunts and freshwater fishing activities take place on other areas of the district. 

There are, however, healthy populations of Sitka black-tailed deer on the three main islands of the PLI 

Wilderness and resident deer hunts are successful. The Forest Service has not received proposals for 

commercial deer hunting activities in PLI Wilderness. 

Table 1 indicates that the only commercial activities to take place in this wilderness area are Remote 

Setting nature Tours (RSNT) and Camping. RSNT includes day use activities such as hiking, exploring, 

wildlife viewing, picnicking, photography, etc. 

Table 2 shows all guides authorized to operate in the PLI Wilderness from 2007 to 2012. This table also 

shows the actual use for each guide and the area of operation by Guide Use Area (GUA). 

Table F3-2. Outfitter/Guides Authorized to Operate on PLI Wilderness (2007-2012)

ACTUAL USE -- Service Days

GUIDE GUA 2007 2008 2009 2010 2011 2012

Chichagof Charters 04-16 0 0 0 0 0 0 

Tok River Outfitters 04-11 0 0 0 0 0 0 

Ken Schoonover 04-11, 04-

16

0 0 0 0 0 0 

Whisper Marine Charters 04-11, 04-

16

0 0 0 0 0 0 

Spirit Walker 

Expeditions of Alaska

04-11,

04-16

174 158 78 101 118 207

Alaska Mtn. Guides 04-11 0 0 0 0 0 0 

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South Passage Outfitters 04-16 0 0 0 0 0 0 

Hobbit Hole Guest House 04-16 X X X 4 6 0 

Eagle Charters 04-16 X X X X 0 0 

Cove Lodge 04-11, 

04-16 

0 0 0 0 0 0 

Icy Strait Adventures 04-11, 

04-16 

0 0 0 0 X X 

Glacier Bay Sport Fishing 04-11, 

04-16 

0 0 0 X X X 

1 A service day is defined as a day, or any part of a day, on National Forest System lands for which an 

outfitter or guide provides goods or services, including transportation, to a client.

• Actual Use is based on outfitter/guide submitted use reports

• X = guide was not under permit to operate on National Forest System lands

• 04-16 – designated Guide Use Area, includes Lemesurier and Inian Islands

• 04-11 – designated Guide Use Area, includes Pleasant Island

Table 2 shows all outfitter/guides authorized to operate on PLI Wilderness. According to the 

outfitter/guide submitted actual use records, all RSNT activities took place on Pleasant Island. There 

were only 10 camping service days recorded from 2007-2012. All camping activities took place on Inian 

Islands.

IV. Evaluation Process for Determination of Public Need

Public need is a need determined to be essential for the well-being of the entire public, guided and 

unguided, or to meet the intent of the Forest’s mission to manage and protect resources, provide for public 

safety, and to provide high quality recreation services. Within wilderness the intended use should be 

dependent on the wilderness resource. A demand for conducting outfitting and guiding activities does not, 

by itself, constitute a need for commercial services.

The criteria used for evaluating the need for outfitter/guide activities in the management of the PLI 

Wilderness include:

Skills and Equipment – outfitter/guide skills and equipment are needed by the public because of one or 

more of the following: 

• Specific skills required for activities appropriate for the area require substantial time and/or talent to

learn.

• Learning necessary skills and participating in the activity requires acquisition and consistent use of

expensive, specialized equipment for which the public could not, or normally would not expend the

time and money.

• The skills required are so unique that the use of a guide is almost a prerequisite if the public is to

have any opportunity to participate in the activity.

Knowledge – guide knowledge of the wilderness resource and the activity area is needed by the public, 

especially nonresident visitors, in order to safely enjoy recreational opportunities in a manner that reduces 

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resource damage and user conflicts. This includes knowing where and by what method to best access and 

travel through an area. 

Safety – an outfitter/guide’s special skills and equipment are needed for a reasonable level of safety for 

the participants. Without guide assistance, members of the public could seriously endanger their health or 

lives, or would not visit the wilderness due to safety concerns. This criterion is not meant to diminish the 

wilderness values of self-reliance or the opportunity to challenge one’s self or experience a degree of risk.

Outfitter/Guide Demand and Utilization – are current outfitted/guide activities booked or over-booked, 

indicating a larger interest in the service?

Management Objectives – outfitter/guides help the Forest Service meet management objectives to: 1) 

provide opportunities for special populations, which include persons with disabilities and the elderly, to 

access certain areas and to participate in recreational and educational activities and , 2) provide 

opportunities for public use, enjoyment, and understanding of the wilderness through experiences that 

depend upon a wilderness setting and are consistent with management of the area as wilderness.

Level of Use and Conflict – conflicts between all users. The extent to which already authorized use days 

or capacity exists for existing permittees to fill the need. What is the compatibility of commercial and 

general public use, and the amount of use and social capacity within a given area of the Wilderness? Are 

trail systems and use patterns (congestion and number of encounters) a potential problem? Is there a 

temporal congestion pattern—weekend use vs. weekday use, day vs. overnight use? Over time, what is 

the general trend? Is the projected future condition compatible with desired future condition? 

Land Capability and Resource Concerns – can the guide contribute to the protection of the land through 

his/her educational emphasis? What is the amount of interference an outfitter/guide operation will have 

with the natural biological and physical processes of the wilderness?

Dependency on Wilderness for Activities – the extent to which the proposed service cannot be offered on 

non-wilderness national forest lands including private or other public lands. Some examples of 

dependence could be: 1) trips in which solitude or unconfined, primitive recreation are the central 

components of the experience; and 2) visits to ecosystems, geological features, or physical resources 

found predominantly in wilderness for recreational, scientific, or educational purposes. 

Wilderness Character – would outfitter/guide activities degrade wilderness character to an unacceptable 

level? Alternatively, could outfitter/guide activities improve wilderness character? 

Forest-Wide Availability – does this activity occur elsewhere in other Wildernesses on the Tongass? For 

example, if an activity occurs in abundance in other areas, there may not be a need to accommodate it in 

the PLI Wilderness area.

Public Purpose – The Wilderness Act section 4(b) specifies “Wilderness areas shall be devoted to the 

public purposes of recreational, scenic, scientific, educational, conservation, and historical use.” Guide 

services must help fulfill these purposes of wilderness. Does this activity contribute to the public 

purposes established for this wilderness? When considering the extent necessary, can people reasonably 

participate in this activity without a guide or is having a guide a prerequisite? Does this activity serve a 

broad segment of the population or limited to a select few? 

V. Evaluation of Activities Authorized for PLI Wilderness Area.

To determine the types of commercial outfitting and guiding activities that could take place in the 

Pleasant/Lemesurier/Inian Islands Wilderness area, the key criteria used to establish public need were 

evaluated for the following authorized activities: 

• Remote Setting Nature Tours

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• Camping

• Freshwater Fishing

• Big Game Hunting

Each criterion was rated based on existing data and information compiled at the Hoonah Ranger District. 

Table F3-3. Evaluation Process for Determination of Public Need

Remote Setting Nature Tours (RSNT)

Criteria Rating Summary

Skills and Equipment High – expert skills and equipment required, high cost for equipment

Knowledge High – local knowledge required, marine navigation and extreme weather

Safety High-Moderate – experienced guides required to provide for safety of visitors

Management Objectives High – guides required

Demand and Utilization High – continued demand for RSNT and Camping activities.

Level of Use and 

Conflict

Low – no conflicts by other outfitter/guides

Land Capability Low – guides emphasize Leave No Trace ethics

Wilderness Dependency High – proximity to Gustavus (base of operations) for RSNT and Camping 

activities. Remote wilderness character required for successful trips

Wilderness Character Low – existing use is low impact

Forest-wide Availability Low – proximity to Gustavus (base of operations), desired use

Public Purpose Moderate – only select groups can afford and participate

Camping

Criteria Rating Summary 

Skills and Equipment High – expert skills and equipment required, high cost for equipment

Knowledge High – local knowledge required due to dangerous shoreline and extreme 

weather

Safety High-Moderate – guides required to provide for safety of visitors and extended trip 

lengths

Management Objectives High – guides required

Demand and Utilization Moderate – low demand for camping

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Level of Use and 

Conflict

Low – no conflicts by other outfitter/guides

Land Capability Low – guides emphasize Leave No Trace ethics

Wilderness Dependency High – wilderness camping and practicing leave no trace is wilderness 

dependent honing wilderness skills.

Wilderness Character Low – existing use is low impact

Forest-wide Availability Low – proximity to Gustavus (base of operations), desired use

Public purpose Moderate – only a select group will participate 

Freshwater Fishing

Criteria Rating Summary

Skills and Equipment High – expert skills and equipment required, high cost for equipment

Knowledge High – local knowledge required due to dangerous shoreline and extreme 

weather conditions 

Safety High-Moderate – guides required to provide for safety of visitors

Management Objectives High – guides required

Demand and Utilization Low – no anadromous fish streams, lakes do not contain game fish

Level of Use and 

Conflict

Low

Land Capability Low – 

Wilderness Dependency Low – fishing is not dependent on wilderness 

Wilderness Character Low

Forest-wide Availability Moderate – several non-wilderness fish stream exist

Public Purpose Low – fishing would address the purpose of recreation and scenic qualities, 

but only a select group will participate 

Big Game Hunting

Criteria Rating Summary

Skills & Equipment High – expert skills and equipment required; equipment can be expensive; 

habitat not known to produce trophy animals

Knowledge High – local knowledge required due to dangerous shoreline and extreme 

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weather conditions

Safety High-Moderate – guides required to provide for safety of visitors

Management Objectives High – guides required

Demand & Utilization Low – no requests for big game hunts. No bear population on PLI 

Wilderness

Level of Use & Conflict Low

Land Capability Low – relatively small area and big game tend to require a larger territory.

Wilderness Dependency Low 

Wilderness Character Low

Forest-wide Availability Moderate: productive hunting areas are available in non-Wilderness areas 

Public Purpose Moderate: guides support recreation purposes of hunting but generally only 

a select group will participate

VI. Determination of Need for Commercial Services

Special Uses Management Direction

To control resource impacts from increased use or to address concerns due to competition between 

outfitter and guide groups and other unguided forest users, the Forest Service developed mitigation 

measures. These mitigation measures are included with all outfitter/guide special use permits as special 

stipulations and therefore become part of the permit. Failure to adhere to the stipulations would be a 

violation of the terms in the special use authorization and could lead to the termination of the permit. 

These mitigation measures evolve in response to current conditions and trends and will continue to be 

used as a management tool to respond to impacts or conflicts that become apparent during the monitoring 

efforts. The current special use stipulations are listed in Appendix 2. 

Recreation Opportunity Spectrum (ROS) 

The Recreation Opportunity Spectrum (ROS) is a system for inventorying recreation experience 

opportunities into seven classes. Each class is defined in terms of the degree to which certain recreation 

opportunities are possible based on the extent to which the natural environment has been modified, types 

of facilities provided, the number of interactions expected with other groups of people, and the relative 

density of recreation use. There are seven classes identified within the Tongass Land Management Plan. 

The PLI Wilderness area consists of Semi-Primitive Motorized and Semi –Primitive Non-Motorized ROS 

Classes. These ROS Classes are defined in Appendix 3.

Assumptions and Evaluation Criteria

Assumptions

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The following are assumptions made to aid in the assessment of the need for outfitter/guide operations: 

• Some people would not visit the PLI Wilderness without an outfitter or guide because they lack the

skills, knowledge, equipment, or ability to do so on their own.

• There will be a continued demand for special use permits to authorize outfitter/guide operations in

the PLI Wilderness area. Access points and use locations are limited to safe harbors and accessible

beaches. Increased demand and use levels at popular locations are issues to consider.

• Overall visitor use is expected to remain at current levels or continue to increase (Forest Plan

Record of Decision 2008). There may also be shifts in use patterns (timing and location) and user

types (hikers, backpackers, day users, etc.).

• Much of the use on PLI Wilderness is incidental. Visitors from fishing boats and pleasure crafts

stop on accessible beaches when weather permits.

• Conflicts between outfitter/guide operations and the non-outfitted/guided public have the potential

to occur if overall use increases.

Evaluation Criteria

The following criteria were used to determine the public need for commercial outfitter and guide services 

in PLI Wilderness: 

• Wilderness Dependence

• Potential Impacts to Wilderness Character

• Knowledge, Skills, and Equipment

• Visitor Safety

• Outfitter and Guide Demand and Utilization

• Public Purpose

Wilderness Dependency

The Forest Plan directs managers to “Avoid authorizing uses that are not dependent upon Wilderness 

resources or uses for which reasonable alternative locations exist outside of Wilderness” (3-12). 

Determination of need is based on the extent to which the proposed service can or cannot be offered on 

non-wilderness National Forest System (NFS) lands or non-NFS lands, including private or other public 

lands. Some examples of wilderness dependence could include 1) trips in which solitude or primitive and 

unconfined recreation are the central components of the experience; and 2) visits to ecosystems, 

geological features, or physical resources found predominantly in wilderness for recreational, scientific, 

or educational purposes.

Potential Impacts to Wilderness Character 

Determination of need is based on the extent to which outfitter and guide activities have the potential to 

degrade or improve wilderness character. The Wilderness Act of 1964 specifies that “each agency 

administering any area designated as Wilderness shall be responsible for preserving the Wilderness 

character of the area (Section 2(c)). Section 2(c) of the Act also defined four qualities of wilderness 

character that managers shall try to preserve, including the following: 

• Untrammeled – The Wilderness is essentially unhindered and free from modern human control or

manipulation. This quality describes the degree to which management actions “hinder” or “control”

the land and natural processes. For example, the Wilderness area has remained free of management

activities that have altered natural systems, such as dams or regulations that govern visitor

activities. Outfitter and guide activities generally do not affect the untrammeled quality of

wilderness character.

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• Natural - Wilderness ecological and evolutionary systems are substantially free from the effects of

modern civilization. This quality describes the ecological effects of human activities on vegetation,

soils, air quality, or other physical and biological components of Wilderness. Outfitter and guide

activities have the potential to impact the natural qualities of wilderness character.

• Undeveloped - Wilderness retains its primeval character and influence and has minimal evidence

of modern human occupation or modification. This quality describes the effects of structures,

habitations, or other evidence of human presence or occupation. Outfitter and guide activities that

require the use of temporary or permanent structures, or create noticeable impacts on the ground,

have the potential to impact the undeveloped qualities of wilderness.

• Outstanding opportunities for solitude or a primitive and unconfined type of recreation. Wilderness

provides outstanding opportunities for people to experience natural sights and sounds, solitude,

freedom, risk, and the physical and emotional challenges of self-discovery and self-reliance.

Outfitter and guide activities have the potential to impact opportunities for solitude in wilderness.

Knowledge, Skills, and Equipment

Determination of need is based on the degree to which outfitter and guide services are needed by the 

public because 1) the specific skills required for activities appropriate to the area require substantial time 

and/or talent to learn; 2) participating in the activity requires acquisition and use of expensive, specialized 

equipment for which the public could not, or ordinarily would not, expend the time and money; and 3) the 

skills, knowledge, and equipment required are so unique that the use of an outfitter or guide is almost a 

prerequisite if area visitors are to have the opportunity to participate safely in the activity. Outfitters and 

guides possess knowledge about the local area and wilderness resource that may be required to safely 

access the area and minimize resource damage and visitor conflicts. This knowledge may include 

knowing where, and by what method, to best access and travel through an area. 

Visitor Safety

Determination of need is based on the degree to which outfitter and guide services are needed by the 

public because of the special skills, knowledge, and equipment needed for a reasonable level of visitor 

safety. Without guide assistance, members of the public and visitors to the area may seriously endanger 

their health or lives, or would not visit the wilderness area due to safety concerns. Outfitter and guide 

services should not diminish other wilderness visitors’ opportunities to experience a degree of challenge 

and risk, and/or sense of self-reliance. 

Outfitter and Guide Demand and Utilization

Determination of need is based on the amount of demand that exists for an outfitter and guide activity and 

the extent to which the activity is already authorized. 

Public Purpose

The Wilderness Act specifies that “Wilderness areas shall be devoted to the public purposes of 

recreational, scenic, scientific, educational, conservation, and historical use” (Section 4(b)). 

Determination of need is based on the extent to which guide services help fulfill these public purposes of 

wilderness. Determination of need is based on the degree to which outfitters and guides help the Forest 

Service meet management objectives to 1) provide opportunities for public use, enjoyment, and 

understanding of the wilderness through experiences that depend upon a wilderness setting and are 

consistent with management of the area as wilderness, and 2) provide opportunities for special 

populations, including persons with disabilities and the elderly, to access certain areas and participate in 

recreational and educational activities.

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VII. Determination of Need for Commercial Services by Activity

Activities Considered

A review of past and current outfitter and guide use in the area surrounding the PLI Wilderness provided 

a starting point for this needs assessment. Based on past use, the following commercial activities were 

considered: 

• Remote Setting Nature Tours

• Camping

• Freshwater Fishing

• Big Game Hunting

This assessment may be revised in the future if recreation use trends and demand for new outfitter and 

guide services is identified. The following individual assessments for each activity include:

Remote Setting Nature Tours

Table F3-4. Remote Setting Nature Tour needs. 

Evaluation 

Criteria

Determination of Need

Wilderness 

Dependency Opportunities for remote setting nature tours exist in the non-wilderness portion of the 

Hoonah Ranger District and surrounding areas of the Tongass National Forest. 

Wilderness, however, provides the remote wild land setting desired for this type of 

activity. PLI Wilderness provides this setting for guided groups originating from 

Hoonah and Gustavus. 

Potential Impact 

to Wilderness 

Character 

Remote setting nature tours occurring in the PLI Wilderness are boat-based and use is 

concentrated on beaches and established trails. As a result, this activities results in 

minimal impacts to vegetation, soil, and water resources. There is a potential for

guided groups to impact opportunities for solitude in the wilderness, particularly if the 

groups are large and use is authorized in popular locations. Motorized boat traffic 

along adjacent waterways also has the potential to reduce opportunities for solitude in 

the PLI Wilderness. Guided remote setting nature tours do not affect the untrammeled 

and undeveloped qualities of wilderness character. 

Knowledge, Skills, 

and Equipment

Visitors must access the PLI Wilderness using motorized boats or float planes. Outfitters and 

guides can provide the skills, equipment, and knowledge required to safely access and enjoy the 

Wilderness.

Visitor Safety Southeast Alaska’s weather conditions and tidal fluctuations can be extreme throughout the year. 

Exposure to wind and cold weather poses a threat to visitor safety. Wildlife encounters also pose a 

risk to safety, although the PLI Wilderness does not provide suitable bear habitat so the risk of 

encounters is minimal.

Outfitter and 

Guide Demand 

and Utilization

There is demand for guided remote setting nature tours in the PLI Wilderness. The 

beaches in PLI Wilderness provide desirable recreation settings for this type of 

activity. PLI Wilderness is also located in close proximity to the City of Gustavus, 

which is a base of operations for guides leading remote setting nature tours. 

(Document could use some clarification earlier about where the visitors originate? I 

assumed the use was from the Icy Strait cruise ships?

Public Purpose Guided remote setting nature tours provide an opportunity for the visiting public to 

- 14 - 
safely access and enjoy the PLI Wilderness for recreational pursuits. Outfitters and 

guides providing remote setting nature tours emphasize Leave No Trace skills and 

outdoor ethics. Remote setting nature tours depend on a wild land setting and are 

consistent with management of the area as wilderness. 

In summary, guided remote setting nature tours occurring in PLI Wilderness are primarily boat-based and 

use is concentrated on beaches and established trails. These activities result in minimal impacts to 

vegetation, soil, and water resources. Authorized outfitters and guides emphasize Leave No Trace skills 

and outdoor ethics. Remote setting nature tours depend on a wild land setting and are consistent with 

management of the area as wilderness.

There is a potential for guided groups to impact opportunities for solitude in the wilderness, particularly if 

the groups are large and use is authorized in popular locations. Group size will be limited to twelve and 

permit stipulations will be designed to reduce potential conflicts with unguided visitors. 

There is demand for guided remote setting nature tours in PLI Wilderness. The beaches in PLI Wilderness 

provide desirable recreation settings for this type of activity. PLI Wilderness is also located in close 

proximity to the communities of Gustavus and Hoonah. Outfitters and guides can provide area visitors with the 

skills, equipment, and knowledge required to safely access and enjoy the Wilderness. There is a need for 

commercially-guided remote setting nature tours in PLI Wilderness. 

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Camping

Table F3-5. Camping Needs. 

Evaluation 

Criteria

Determination of Need

Wilderness 

Dependence Opportunities for guided camping exist in the non-wilderness portion of the Hoonah 

Ranger District and surrounding areas of the Tongass National Forest. Wilderness, 

however, provides the remote wild land setting desired for this type of activity. PLI 

Wilderness provides this setting for guided groups originating from Hoonah and 

Gustavus. Wilderness also provides an opportunity for guided visitors to practice 

Leave No Trace camping skills and learn about outdoor ethics. 

Potential Impact 

to Wilderness 

Character 

Guided camping generally occurs on the beaches along the shoreline of PLI 

Wilderness and results in minimal impacts to vegetation, soil, and water resources. 

There is a potential for guided groups to impact opportunities for solitude in the 

wilderness, particularly if the groups are large or use is authorized in popular locations. 

Motorized boat traffic along adjacent waterways also has the potential to reduce 

opportunities for solitude. Guided camping tours do not affect the untrammeled and 

undeveloped qualities of wilderness character.

Knowledge, Skills, 

and Equipment Visitors must access the PLI Wilderness using motorized boats or float planes. Outfitters and 

guides can provide the skills, equipment, and knowledge required to safely access and enjoy the 

Wilderness. Guides also provide the skills, equipment, and knowledge needed to minimize impacts 

from overnight visitors. 

Visitor Safety Southeast Alaska’s weather conditions and tidal fluctuations can be extreme throughout the year. 

Exposure to wind and cold weather poses a threat to visitor safety. Wildlife encounters also pose a 

risk to safety, although the PLI Wilderness does not provide suitable bear habitat so the risk of 

encounters is minimal. 

Outfitter and 

Guide Demand 

and Utilization

There is demand for guided camping services for the PLI Wilderness. Where? 

Beaches? 

Public Purpose Guided camping tours provide an opportunity for the visiting public to safely access 

and enjoy the PLI Wilderness for recreational pursuits. Outfitters and guides providing 

camping tours emphasize Leave No Trace skills and outdoor ethics. Campers often 

seek a wild land setting and this activity is consistent with the management of the area 

as wilderness. 

In summary, guided camping generally occurs on the beaches along the shoreline of PLI Wilderness and 

results in minimal impacts to vegetation, soil, and water resources. As a result, these activities result in 

minimal impacts to vegetation, soil, and water resources. Wilderness also provides an opportunity for 

guided visitors to practice Leave No Trace camping skills and learn about outdoor ethics. Backcountry 

camping experiences depend on a wild land setting and are consistent with management of the area as 

wilderness.

There is a potential for guided groups to impact opportunities for solitude in the wilderness, particularly if 

the groups are large and use is authorized in popular locations. Group size will be limited to twelve and 

permit stipulations will be designed to reduce potential conflicts with unguided visitors. 

- 16 - 
There is demand for guided camping tours in PLI Wilderness. The beaches in PLI Wilderness provide 

desirable recreation settings for this type of activity. PLI Wilderness is also located in close proximity to 

the communities of Gustavus and Hoonah. Outfitters and guides can provide area visitors with the skills, 

equipment, and knowledge required to safely access and enjoy the Wilderness. There is a need for commerciallyguided camping in PLI Wilderness. 

Freshwater Fishing

Table F3-6. Freshwater Fishing needs.

Evaluation 

Criteria

Determination of Need

Wilderness 

Dependence

Several streams in non-wilderness National Forest System lands on the Hoonah Ranger 

District and surrounding areas of the Tongass National Forest support anadromous fish 

populations and provide excellent freshwater fishing opportunities. 

Potential Impact 

to Wilderness 

Character 

The majority of freshwater fishing in the non-wilderness portion of the northern 

Tongass National Forest is boat-based and results in minimal impacts to vegetation, soil, 

and water resources. ADF&G provides sport fishing guidelines that help maintain the 

natural quality of wilderness character through the sustainable management of fish 

populations. Guided fishing activities do not impact the undeveloped quality of

wilderness character. Guided groups have the potential to impact opportunities for 

solitude, particularly if the groups are large and use is authorized in popular locations.

Knowledge, Skills, 

and Equipment Visitors must access the PLI Wilderness using motorized boats or float planes. Outfitters and guides 

can provide the skills, equipment, and knowledge required to safely access and enjoy the 

Wilderness.

Visitor Safety Southeast Alaska’s weather conditions and tidal fluctuations can be extreme throughout the year. 

Exposure to wind and cold weather poses a threat to visitor safety. Wildlife encounters also pose a 

risk to safety, although the PLI Wilderness does not provide suitable bear habitat so the risk of 

encounters is minimal.

Outfitter and 

Guide Demand 

and Utilization

There are no streams in the PLI Wilderness that support anadromous fish species (e.g. 

salmon, steelhead). The lakes in PLI Wilderness also do not provide suitable habitat for 

game fish. While authorized, there is no reported freshwater fishing by guides over the 

last five years.

Public Purpose There is little to no public interest in guided fishing in the PLI Wilderness.

In summary, there are no streams or freshwater lakes in the PLI Wilderness that support anadromous fish 

such as salmon and steelhead. Although authorized, there has been no reported use for this activity by 

guides over the last five years. Opportunities for freshwater fishing are available on the non-wilderness 

portions of the Hoonah Ranger District and surrounding areas on the northern part of the Tongass 

National Forest. Given the lack of anadromous fish species and interest in outfitting and guiding permits 

for freshwater fishing, there is no commercial need for this activity in PLI Wilderness. 

- 17 - 
Big Game Hunting

Table F3-7. Big Game Hunting needs.

Evaluation 

Criteria

Determination of Need

Wilderness 

Dependence Opportunities for big game hunting exist on non-wilderness National Forest System 

lands of the Hoonah Ranger District and surrounding areas of the Tongass National 

Forest. Private lands near Hoonah also provide some opportunities for guided big game 

hunts. 

Potential Impact 

to Wilderness 

Character 

The majority of hunting in PLI Wilderness and surrounding areas on the Tongass 

National Forest is boat-based and results in minimal impacts to vegetation, soil, and 

water resources. ADF&G provides recommendations, population estimates, and 

historical harvest data to help the Forest Service determine the number of guided hunts 

an area can sustain, thereby ensuring that the natural quality of wilderness character is 

maintained. Guided hunting groups have the potential to impact the undeveloped quality 

of wilderness if tent platforms are constructed. Guided groups also have the potential to 

impact opportunities for solitude, particularly if the groups are large and use is 

authorized in popular locations.

Knowledge, Skills, 

Equipment 

Visitors must access the PLI Wilderness using motorized boats or float planes. Outfitters and guides 

can provide the skills, equipment, and knowledge required to safely access and enjoy the 

Wilderness. The Alaska Department of Fish and Game (ADF&G) requires non-resident 

brown bear hunters to be accompanied by a registered guide or a relative within the 

second degree of kin. The knowledge and skills required to identify male bears and 

properly care for the animal carcass in accordance with State law are beyond the 

average person’s abilities. 

Visitor Safety Southeast Alaska’s weather conditions and tidal fluctuations can be extreme throughout the year. 

Exposure to wind and cold weather poses a threat to visitor safety. Wildlife encounters also pose a 

risk to safety, although the PLI Wilderness does not provide suitable bear habitat so the risk of 

encounters is minimal.

Outfitter and 

Guide Demand 

and Utilization

There is low demand for guided big game hunting authorizations for the PLI 

Wilderness. The islands within the Wilderness do not provide bear habitat, but do 

provide habitat for deer. Though there are healthy populations of Sitka black-tailed deer 

on all of the PLI islands, there has been no request for commercially guided deer hunts. 

While resident hunters access the area for deer hunting, there has been no guided big 

game hunting reported in this area between 2008 and 2012. 

Public Purpose There is little to no public interest in guided fishing in the PLI Wilderness. Federallyqualified subsistence hunters hunt on some of PLI islands. Permitting commercial deer 

hunts could result in conflict between guided sport hunters and subsistence hunters. 

In summary, PLI Wilderness does not provide suitable habitat for big game species such as brown and 

black bear. The Wilderness does provide habitat for Sitka black-tailed deer, but there has been no demand 

or use of guided deer hunting services documented in past years. There is no State requirement for a 

registered guide for deer hunting. Deer are commonly hunted without a guide throughout Southeast 

Alaska. While wildlife encounters may pose a risk to hunter safety, deer hunting does not pose the safety 

challenges associated with black and brown bear hunting. Opportunities for big game hunting are 

available on the non-wilderness portion of the Hoonah Ranger District and surrounding areas on the 

northern part of the Tongass National Forest. Given the lack of suitable habitat and interest in outfitting 

- 18 - 
and guiding permits for big game hunting, there is no commercial need for this activity in PLI 

Wilderness. 

VIII. Summary

This needs assessment was developed to determine the public need for commercial outfitter and guide 

services in the PLI Wilderness. Public need is identified for services that are required to meet the Forest 

Service’s mission to manage and protect the resources, provide for visitor safety, and provide high-quality 

recreation opportunities. 

Based on the evaluation of the existing commercial activities on the PLI Wilderness area, a need has been 

identified for commercially-guided Remote Setting Nature Tours and Camping. A need has not been 

identified for commercially-guided big game hunting or freshwater fishing in the PLI Wilderness.

Decision

The determination of need for commercially outfitter and guide services on the PLI Wilderness is as 

follows: 

• Remote Setting Nature Tours: It is recommended that commercially guided remote setting

nature tours should be authorized in the PLI Wilderness area through this needs assessment.

• Camping: It is recommended that commercially guided camping should be authorized in the

PLI Wilderness area through this needs assessment.

• Freshwater Fishing: It is recommended that commercially guided fresh water fishing should

not be authorized in the PLI Wilderness area through this needs assessment.

• Big Game Hunting: It is recommended that commercially guided big game hunting should

not be authorized in the PLI Wilderness area through this needs assessment.

Commercially guided Remote Setting Nature Tours and Camping activities will only be authorized to the 

extent consistent with the Wilderness Act of 1964’s direction to maintain wilderness character. 

It is important to note that a determination of need does not imply that a commercial activity will be 

authorized for all locations in the PLI Wilderness. This document does not fully address the effects (e.g. 

social, physical) of existing and proposed commercial uses. Decisions regarding the appropriate types and 

levels of commercial use in particular locations will be accomplished in compliance with the National 

Environmental Policy Act (NEPA). 

- 19 - 
Appendix 1. Wilderness Management Direction

The Wilderness Act of 1964

The Wilderness Act of 1964 states the purpose of Wilderness is “to secure for the American people of 

present and future generations the benefits of an enduring resource of Wilderness.” Wilderness being an 

area “affected primarily by the forces of nature, with the imprint of man’s work substantially 

unnoticeable;” . . . “has outstanding opportunities for solitude or a primitive unconfined type of 

recreation; . . . and “may also contain ecological, geological, or other feature of scientific, educational, 

scenic, or historical value.” 

The Wilderness Act also describes how Wilderness areas are to be used and managed. Management is to 

focus on preserving the Wilderness character of the area; and use of the area “shall be devoted to the 

public purposes of recreational, scenic, scientific, education, conservation, and historical uses.” In 

realizing these uses Wilderness provides an opportunity for solitude or primitive unconfined types of 

recreation not attainable in settings more man-made, or influenced by humans. 

In accomplishing the purpose of, and uses of Wilderness, the Wilderness Act gives some additional 

direction. Specifically, with one notable exception commercial enterprises are prohibited by Section 4(c) 

of the Act. The exception covered in Section 4(d) (6) says; “commercial services may be performed 

within the Wilderness area . . . to the extent necessary for activities which are proper for realizing the 

recreation or other Wilderness purposes of the areas.” 

Alaska National Interest Lands Conservation Act of 1980 (ANILCA)

Section 707 of ANILCA states; “Except as otherwise expressly provided for in this Act, Wilderness 

designated by this Act shall be administered in accordance with applicable provisions of the Wilderness 

Act ...” 

Items expressly provided for in ANILCA Wilderness are many. Some include; 

• Section 811 – Reasonable access for subsistence resource uses

• Section 1010 – Mineral assessments with access by air.

• Section 1110(a) – Special Access allowing for the use of airplanes, motorboats, and

snowmachines (during periods of adequate snow) within conservation system units as defined

by Section 102 (4). These rights may be subject to reasonable regulation to protect the natural

and other values of the conservation system units.

• Section of 1303(b)(1) – Allowance for the construction of new cabins and administrative

cabins if necessary for the administration of the area as Wilderness

• Section 1303(b) (2) – Allowance for the continuation of existing cabins.

• Section 1310 – Allowing for the maintenance of existing and future navigation aids and other

facilities.

• Section 1315(c) – Permitting the continued use and maintenance of public use cabins. 1315(d)

allows for the construction of new cabins if they’re necessary for the protection of pubic

health and safety.

• Section 1316(a) – Allows for existing and future establishment of temporary structures

necessary for the taking of fish and game subject to reasonable regulation to insure

compatibility, the continuance of existing uses, and the future establishment, and use, of

temporary campsites, tent platforms, shelters, and other temporary facilities and equipment

directly and necessarily related to such activities. Section 1316(b) allows for the denial of the

- 20 - 
temporary facilities if the use of equipment or facilities is determined to be detrimental to the 

Wilderness character.

ANILCA exceptions may influence the character of some Wildernesses more than others. During the 

evaluation of commercial recreation use for any one Wilderness, an effort should be made to consider the 

long-term effects of accommodating increasing uses or proposals for new use. The economic benefits to 

a business are not a substantive basis of a decision to allow use presented in either the Wilderness Act or 

ANILCA.

Direction Provided by Regulation

Federal Regulations 36 CFR 293.2 – Objectives, states in part: “Except as otherwise provided in the 

regulations..., National Forest Wilderness shall be so administered as to meet the public purposes of 

recreational, scenic, scientific, educational, conservation, and historical uses; and it shall also be 

administered for such other purposes for which it may have been established in such a manner as to 

preserve and protect its Wilderness character...To that end:

(a) Natural ecological succession will be allowed to operate freely to the extent feasible.

(b) Wilderness will be made available for human use to the optimum extent consistent with the

maintenance of the primitive conditions.

(c) In resolving conflicts in resource use, Wilderness values will be dominant to the extent not limited

by the Wilderness Act, subsequent establishing legislation, or the regulations in this part.” 

Federal Regulations 36 CFR 293.8 - Permanent structures and commercial services, states in part that: 

“The Chief, Forest Service, may permit . . . commercial services within National Forest Wilderness to the 

extent necessary for realizing the recreational or other Wilderness purposes, which include, but are not 

limited to, the public services generally offered by packers, outfitters, and guides.” 

Agency Direction

USDA Forest Service Strategic Plan FY 2007-2012

The mission of the USDA Forest Service is based on the relationship between the American people and 

their natural resource heritage. The relationship is founded on the principles of sustaining U.S. natural 

resources for future generations, producing personal and community well-being, and providing economic 

wealth for the Nation. 

The Strategic Plan embodies the Forest Service’s many areas of responsibility, as captured in the agency’s 

mission statement: 

“The mission of the USDA Forest Service is to sustain the health, diversity, and productivity of the 

Nation’s forest and grasslands to meet the needs of present and future generations.” 

One of the many goals of the Strategic Plan is to provide high-quality outdoor recreational opportunities 

on forests and grasslands, while sustaining natural resources, to meet the Nation’s recreational demands. 

- 21 - 
Forest Service Chief’s 10-Year Wilderness Stewardship Challenge

In 2005, the Chief of the Forest Service adopted the 10-year Wilderness Stewardship Challenge (WSC) as 

recommended by the Chief’s Wilderness Advisory Group. This effort is a renewal of the commitment to 

Wilderness by pledging to bring all 406 Wildernesses administered by the Forest Service to a minimum 

level of stewardship within 10 years. Element 7 of the WCS identities that, “Needs assessments are 

completed for new operations or for major changes to existing outfitter programs” [emphasis 

added]. As clarified in the definitions for this element; ““needs assessments”; a methodology for 

determining if, in fact, there is a “need” for private enterprise to assist the Agency in providing access, 

services and/or other assistance for the recreating public to safely and properly enjoy National Forest 

Wilderness.” 

Another part of the WSC related to forest plan management direction is Element 5 – Protecting 

Opportunities for Solitude or Primitive and Unconfined Recreation. Managing to protect “outstanding 

opportunities for solitude or a primitive and unconfined type of recreation” has been perhaps the most 

controversial aspect of Wilderness management to date. Controversy typically emerges if managers 

propose any type of restriction on visitor access or behavior, such as use limits, to improve opportunities 

for solitude. Factors contributing to this controversy include: 

• Lack of clarity over the meaning of solitude thus leading to lack of agreement over what the

problem really is (e.g. visitors may view the concept holistically while managers may focus on

the number of encounters in particular locations).

• Perception that solitude is too subjective and individualistic to manage for.

• Lack of standards or agreement on standards that define when there is a problem requiring

corrective action.

• Managing for solitude without equal consideration of managing for primitive and unconfined

recreation opportunities.

• The importance of access to visitors even when they support Wilderness preservation.

• Tension between providing outstanding opportunities for solitude vs. primitive and unconfined

recreation.

Forest Service Direction

Outfitters/guides must also meet agency objectives. These objectives are specifically outlined in the 

Forest Service Manuals (FSMs) and Forest Service Handbooks (FSHs). 

FSM 2702 Special Uses Management states: The objectives of the special-uses program are to:

• Authorize and manage special uses of National Forest System lands in a manner which

protects natural resources and public health and safety, consistent with National Forest

System Land and Resource Management Plans;

• Administer special; uses based on resource management objectives and sound business

management principles;

• Develop and maintain a well-trained workforce to properly manage and administer special

uses; and

• Facilitate the delivery of recreational opportunities on National Forest System lands for

services not provided by the Forest Service.

- 22 - 
Forest service special use objectives specifically for outfitting and guiding, provided in FSH 2709.14, 

Chapter 50, Section 53.1b states:

• Provide for outfitting and guiding services that address concerns of public health and safety

and that foster successful small businesses consistent with the applicable land management

plan.

• Facilitate greater participation in the outfitting and guiding program by organizations and

businesses that work with youth and educational groups.

• Encourage skilled and experienced individuals and entities to conduct outfitting and guiding

activities in a manner that protects environmental resources and ensures that national forest

visitors receive high-quality services.

Forest Service Special Use policy for outfitting and guiding provided in FSH 2709.14, Chapter 50, 

Section 53.1c states: 

• Authorize only those outfitting and guiding activities that are consistent with the applicable

land management plan and that meet the screening criteria in 36 CFR 251.54(e) and FSH

2709.11, chapter 10.

• Not authorize any development or permanent improvements in non-wilderness in the National

Forest System for outfitting and guiding services, except when there is a demonstrated public

need and the structures, improvements, or installations have negligible value and minimal

impact on national forest resources, as with hitching posts, corrals, tent frames, permitted

access routes, and shelters.

• Not authorize any development, improvements, or installations in wilderness areas for the

purpose of convenience to the holder or the holder’s clients; caches in wilderness areas; and

permanent structures, improvements, or installations in wilderness areas unless they are

necessary to meet minimum requirements for administration of the area for the purposes of the

Wilderness Act (16 U.S.C. 1133c).

• Work with other Federal agencies, State and local authorities, outfitters and guides, outfitting

and guiding organizations, and other interested parties to ensure that outfitting and guiding

activities are consistent with applicable laws and regulations and to identify unauthorized

outfitting and guiding activities. Follow procedures in FSM 5300 in investigating and

preventing the occurrence of unauthorized outfitting and guiding activities.

Forest Service policy addressing outfitter and guide operations in wilderness found in FSM 2323.13g 

states that mangers should;

Address the need for and role of outfitters in the forest plan. The plan must address the type, 

number, and amount of recreation use that is to be allocated to outfitters. Ensure that outfitters provide 

their service to the public in a manner that is compatible with use by other wilderness visitors and that 

maintains the wilderness resource.

Objectives for wilderness management provided in FSM 2323.11 are to: 

• Provide, consistent with management of the area as wilderness, opportunities for public use,

enjoyment, and understanding of the wilderness, through experiences that depend upon a

wilderness setting.

- 23 - 
• Provide outstanding opportunities for solitude or a primitive and unconfined type of

recreation.

Forest Service policy addressing recreation management in wilderness is ++found in FSM 2323.12 states: 

• Maximize visitor freedom within the wilderness. Minimize direct controls and restrictions.

Apply controls only when they are essential for protection of the wilderness resources and

after indirect measures have failed.

• Use information, interpretation, and education as the primary tools for management of

wilderness visitors.

• Manage for recreation activities that are dependent on the wilderness environment so that a

minimum of adaptations within wilderness are necessary to accommodate recreation.

• Consistent with management as wilderness, permit outfitter/guide operations where they are

necessary to help segments of the public use and enjoy wilderness areas for recreational or

other wilderness purpose.

Forest Plan Direction for Wilderness (pages 3-7 to 3-25)

Goals

To manage all designated Wilderness to maintain an enduring Wilderness resource while providing for 

public access and uses consistent with the Wilderness Act of 1964 and the Alaska National Interest Lands 

Conservation Act of 1980 (ANILCA). 

Protect and perpetuate natural biophysical and ecological conditions and processes. Ensure Wilderness 

ecological systems are substantially free from the effects of modern civilization.

To provide a high degree of remoteness from the sights and sounds of humans, and opportunities for 

solitude and primitive recreation activities consistent with Wilderness preservation.

Keep Wilderness untrammeled and free from modern human control or manipulation, including actions 

taken to manage Wilderness.

Protect the undeveloped character of Wilderness by following legislative guidelines regarding permanent 

improvements or modern human occupation, including mechanized transport and motorized equipment. 

Objectives

• Apply a multi-disciplinary focus to Wilderness management. The stewardship of the Wilderness is

considered in the annual program of work by all resources.

• Manage recreation activities so the levels of social encounters, on-site developments, methods of

access, and visitor impacts indicated for the Primitive Recreation Opportunity Class are

emphasized. Areas managed as semi-primitive within a Wilderness are an exception and are not

encouraged. .

• Provide for public use of the Wilderness in accordance with ANILCA provisions for motorized and

non-motorized access and travel, including reasonable traditional subsistence use by rural

residents.

• Maintain trails and primitive facilities that are in harmony with the natural environment and that

promote primitive recreation opportunities. Feature facilities designed primarily to provide

resource protection and encourage smaller group size. Facilities tend to allow for challenge and

risk instead convenience.

- 24 - 
• Maintain the Wilderness capacity to provide information on natural ecological processes

• Preserve and perpetuate biodiversity

• Inventory, reduce, and when possible, eliminate non-native species in Wilderness

• Manage Wilderness as a place where self reliance and primitive skills are needed and can be

honed.

Desired Condition

All designated Wilderness on the Tongass National Forest is characterized by extensive, unmodified 

natural environments. Ecological processes and natural conditions are not measurably affected by past or 

current human uses or activities. Users have the opportunity to experience independence, closeness to 

nature, solitude and remoteness, and may pursue activities requiring self-reliance, challenge and risk. 

Motorized and mechanized use is limited to the minimum needed for the administration of the 

Wilderness. Allow for access to state and private lands, subsistence uses, and for public access and other 

uses to the extent provided by ANILCA. If not specifically provided through an ANILCA exception, the 

resources within a designated Wilderness shall be administered in accordance with the applicable 

provisions of the Wilderness Act.

The Forest Plan notes that; “Special Use Authorizations permitting individuals or organizations to provide 

visitor services in Wilderness may be issued if there is a demonstrated need for the service(s) and they are 

deemed appropriate for the area proposed.”

- 25 - 
Appendix 2. Special Use Permit Stipulations for Outfitting and 

Guiding on National Forest System Lands, Tongass National Forest

SPECIAL STIPULATIONS

The first group of stipulations apply to all National Forest System lands covered by this permit. These are 

followed by lists of stipulations specific to individual Forest Service Administrative Units.

All Areas Within The Scope Of This Permit

A copy of the permit (with current operating plan, maps, amendments, or other attachments), must be 

with the permit holder, or accessible at all times to all employees, when operating on National Forest 

System lands. The number of copies of the permit needed in the field to comply with this requirement is 

the responsibility of the permit holder. An operator providing ancillary service for only point-to-point 

transport of clients to and from the field will not be required to copy the permit but must be able to 

identify the permit holder to whom the services are being provided if asked.

Land ownership is mixed and it is the responsibility of the permit holder to determine ownership and 

obtain proper authorization for use of private, native, and/or local government-held lands. 

Outfitter-guides will incorporate “Leave No Trace” skill into all activities on National Forest in 

accordance with the Appendix.

In a congressionally designated wilderness, no more than two groups of 12 people or less (including 

guides) from a single vessel or other means of transport or access are allowed. No more than 24 

individuals from a vessel may use a specific wilderness in a single day. These groups are required to 

disperse out of sight and sound from each other when using National Forest System lands to minimize 

impacts to a specific site or others using the area. 

When viewing wildlife, outfitters and guides are required to adhere to the following resource protection 

measures (Tongass Land and Resource Management Plan, 2008)

• Marine Mammals: Operators will comply with the National Marine Fisheries Service Marine

Mammal Viewing Guidelines and Regulations.

• Mountain Goats: Mountain goats are present in subalpine/alpine habitat and are particularly

sensitive to disturbance during the winter through the kidding season (approximately June

15). Aircraft should maintain a 1, 500 meter- 2 kilometer [4,921 - 6,562 ft] horizontal distance

and a minimum 500 meter [1,640 ft] vertical distance from goats. Limit other activities in

subalpine/alpine ecosystem and avoid approaching or conducting other activities that elicit

fright/flight behavior in goats (nervous glancing around, walking, running).

• Seabird Breeding Colonies: a). Maintain a 250 meter no-disturbance distance from seabird

colonies on upland habitats. b) When weather ceilings permit, maintain a constant flight

direction and airspeed and a minimum flight elevation of 1,500 feet (458 meters) for

helicopters and fixed-winged aircraft. If at all possible, avoid flying over seabird colonies

• Waterfowl and Shorebird Habitats: To reduce human disturbance, provide a minimum

distance of 330 feet (100 meters) between human activities on the ground and significant

areas being used by other waterfowl.

- 26 - 
• Bald Eagle Nest Sites: If the activity will be visible or highly audible from the nest, maintain a

330-foot buffer during the breeding season. See National Bald Eagle Management Guidelines

for additional considerations.

Karst and Cave Resources: Outfitter/guides will protect karst and cave resources as required by the 

Federal Cave Resources Protection Act (FCPRA). Cave use is not permitted without an approved Cave 

Protection plan (Tongass Resource and Land Management Plan, 2008). 

Beach Meadows: To minimize impacts to beach meadows, outfitter/guides and their clients will not camp 

in these areas. When walking through these areas, people should stay on existing paths and game trails to 

avoid trampling or damaging vegetation in beach meadows (Tongass Land and Resource Management 

Plan, 2008). 

Plant species shall not be collected without a Forest Products Permit. Sightings of listed sensitive plants 

should be reported to the Forest Service. The updated sensitive plant list can be found at this website: 

(http://fsweb.r10.fs.fed.us/staffs/wfew/index_wfew.shtml) 

Use Reports are required to be submitted within the timeframes identified by the permit and according to 

the instructions. Use Reports that are incomplete or illegible may be returned to the permit holder for 

corrections. Use Reports that are late, incomplete or illegible may be a factor in the year-end performance 

evaluation and can result in a notice of non-compliance.

- 27 - 
Appendix 3. ROS Classes for PLI Wilderness (Tongass Land and 

Resource Management Plan 2008 )

Semi-Primitive Non-Motorized

Table F3-8. Setting indicators, standards, and guidelines. 

Setting 

indicators

Standards and Guidelines

Scenic Quality Not to exceed the High Scenic Integrity Objective. An Existing Scenic Integrity 

level of Very High is fully compatible and encouraged

Access Non-motorized cross-country travel and travel on non-motorized trails is typical. 

Use of airplanes, helicopters, motorboats, and snowmachines for traditional 

activities, subsistence, emergency search and rescue, and other authorized resource 

management activities may occur unless specifically restricted for safety and/or 

resource protection purposes. Use of off-highway vehicles may occur on designated 

routes in accordance with 36 CFR 212, 251, and 261 – Travel Management; 

Designated Routes and Areas for Motor Vehicle Use.

Remoteness Nearby sights or sounds of human activity are rare, but distant sights or sounds may 

occur. Setting is located more than 0.5 hour walk or paddle, or approximately 0.5 

mile (grater or less depending on terrain and vegetation, but no less than 0.25 mile) 

from 1) infrequently traveled waterways; 2) roads and trails open to motorized 

recreation use; and 3) clearcut harvest areas. Aircraft access is only occasional. 

Areas are generally greater than 2,500 acres, but may be smaller if contiguous with 

Primitive or Semi-Primitive class.

Visitor 

Management

On-site regimentation and controls are rare. Visitor information facilities may be 

used to interpret cultural and natural resource features, but are not elaborate and 

harmonize with the setting.

On-site 

Recreation

Development

Facilities and structures generally do not exceed Development Scale II and are 

maintained to accommodate the types and levels of use anticipated for the site. 

Forest Service recreation cabins are fully compatible. 

Social 

Encounters 

User meets less than 10 parties per day (6 parties per day in Wilderness) on trails 

and waterways during 80 percent of the primary use season. No other parties are 

within sight or sound of dispersed campsites during 80 percent of the primary use 

season. Maximum party size for commercial use within Wilderness is 12. 

Exceptions for larger party sizes within Wilderness should be rare. Refer to 

REC122 in Chapter 3 for exceptions. A party size of up to 20 people can be 

considered in Semi-Primitive settings outside of Wilderness. Outside of 

Wilderness, party sizes larger than 20 people may occur during less than 15 percent 

of the primary use season in limited locations as appropriate by LUD.

Visitor Impacts Visitor-caused impacts to resources are rare and usually not long-lasting. Site 

hardening is limited to boardwalk trails, boat tramways, moorings and docks, bearproof food cache facilities, and rustic public recreation cabins.

- 28 - 
Semi-Primitive Motorized 

Table F3-9. Semi-Primitive motorized setting indicators, standards and guidelines. 

Setting 

indicators

Standards and Guidelines

Scenic Quality Not to exceed the Moderate Scenic Integrity Objective. Existing Scenic Integrity 

levels ranging from Very High through High are fully compatible and encouraged.

Access Travel on motorized and non-motorized trails and Traffic Service Level D roads, 

although some Traffic Service Level C roads provide access to and through the 

area. Use by high-clearance vehicles and motorized water travel is common. Road 

density is less than 1 mile per square mile. Off-road snowmachine travel on snow 

may occur.

Remoteness Nearby sights or sounds of human activity are rare, but distant sights or sounds may 

occur. Setting is located within 0.5 hour walk or paddle or within 0.5 mile (greater

or less depending on terrain and vegetation, but no less than 0.25 mile) of 

infrequently traveled waterways or small aircraft access points and/or roads that are 

open and maintained for passage by high-clearance and four-wheel drive vehicles 

(Maintenance Level 2), and provide access to recreation opportunities and facilities. 

Areas are generally greater than 2,500 acres, but may be smaller if contiguous with 

Primitive or Semi-Primitive Non-Motorized classes.

Visitor 

Management

On-site regimentation and controls are few. Control facilities consist primarily of 

informational signs and site-specific road closures. Visitor information facilities 

may be used to interpret cultural and natural resource features, but are not elaborate 

and harmonize with the setting.

On-site 

Recreation

Development

Facilities and structures generally do not exceed Development Scale II and are 

maintained to accommodate the types and levels of use anticipated for the site and 

area. Forest Service recreation cabins are fully compatible.

Social 

Encounters 

User meets less than 10 parties per day (6 parties per day in Wilderness) on trails, 

roads, and shorelines during 80 percent of the primary use season. During 80 

percent of the primary use season, no other parties are visible from campsites. 

Maximum party size for commercial uses in Wilderness is 12 people. Exceptions 

should be rare. Refer to REC122 in Chapter 3 for exceptions. A party size of up to 

20 people can be considered in Semi-Primitive settings outside of Wilderness. 

Outside of Wilderness, party sizes larger than 20 people may occur during less than 

15 percent of the primary use season in limited locations.

Visitor Impacts Visitor-caused impacts may be noticeable, but not degrading to basic resource 

elements. Site hardening is very infrequent, but, when it occurs, is in harmony with, 

and appropriate for, the natural-appearing backcountry setting.

- 29 - 
Determination of Need for Commercial Outfitter/Guide 

Services in the West Chicagof-Yakobi Wilderness

Sitka and Hoonah Ranger Districts, Tongass National Forest

- 1 - 
Table of Contents 

Executive Summary ................................................................................................................ - 3 -

Introduction ............................................................................................................................. - 3 -

West Chichagof - Yakobi Wilderness..................................................................................... - 5 -

Area Description .............................................................................................................................. - 5 -

Commercial Visitor Use................................................................................................................... - 6 -

Determination of Need for Commercial Services – ................................................................ - 8 -

Assumptions and Evaluation Criteria ..................................................................................... - 8 -

Assumptions ..................................................................................................................................... - 8 -

Evaluation Criteria .................................................................................................................. - 8 -

Wilderness Dependence ................................................................................................................... - 9 -

Potential Impacts to Wilderness Character ...................................................................................... - 9 -

Knowledge, Skills, and Equipment Required ................................................................................ - 11 -

Visitor Safety ................................................................................................................................. - 12 -

Outfitter and Guide Demand and Utilization ................................................................................. - 12 -

Public Purposes / Management Objectives .................................................................................... - 12 -

Determination of Need for Commercial Services by Activity ....................................................... - 12 -

Appendix A. Management Direction .................................................................................... - 21 -

The Wilderness Act of 1964 .......................................................................................................... - 21 -

Alaska National Interest Lands Conservation Act of 1980 (ANILCA) ......................................... - 21 -

Direction Provided by Regulation .................................................................................................. - 22 -

Forest Service Manual and Handbook Direction ........................................................................... - 22 -

Tongass National Forest Land and Resource Management Plan Direction for Wilderness (pages 3-7 

to 3-25) ........................................................................................................................................... - 24 -

- 2 - 
Executive Summary

This document applies to the criteria of Section 4(d)6 of the Wilderness Act of 1964 (“Wilderness Act”) 

to determine which commercial recreation service activities may be necessary in the West ChichagofYakobi Wilderness. 

Commercial services may be performed within the wilderness areas designated by this Act to the 

extent necessary for activities which are proper for realizing the recreational or other wilderness 

purposes of the areas.

This assessment pertains solely to commercial recreation service activities. It does not consider other 

commercial or noncommercial uses. The need for commercial recreation service activities is determined 

by their ability to realize the recreational or other wilderness purposes of the Wilderness Act and their 

compatibility with preserving wilderness character.

This assessment concludes with a determination of need for six commercial recreation service activities in 

the West Chichagof-Yakobi Wilderness. Need was determined with a set of evaluation criteria that 

assessed the ability of activities to fulfill the purposes of the Wilderness Act and compatibility with 

preserving wilderness character. Market-generated demand for conducting outfitter and guide activities 

does not, by itself, constitute a need for commercial services. Identification of need also considers how an 

outfitter and guide operation can contribute to meeting the Tongass Land and Resource Management Plan 

(USDA Forest Service 2008b) management objectives. The following summarizes the findings. 

Determination of Need for Commercial Service Activities:

• Big Game Hunting for Brown Bear commercial service activities are necessary in the West

Chichagof-Yakobi Wilderness

• Big Game Hunting for Deer commercial service activities are necessary in the West ChichagofYakobi Wilderness

• Camping (including overnight use of public recreation cabins) commercial service activities are

necessary in the West Chichagof-Yakobi Wilderness

• Floatplane Landing Tours commercial service activities are not necessary in the West

Chichagof-Yakobi Wilderness

• Freshwater Fishing commercial service activities are necessary in the West Chichagof-Yakobi

Wilderness

• Remote Setting Nature Tours commercial service activities are necessary in the West ChichagofYakobi Wilderness

It is important to note that a determination of need does not imply that a commercial activity will be 

authorized for all locations in the West Chichagof-Yakobi Wilderness. This document does not fully 

address the effects (e.g. social, physical) of existing and proposed commercial uses. Decisions regarding 

the appropriate types and levels of commercial use in particular locations will be accomplished in 

compliance with the National Environmental Policy Act. Guided activities will only be authorized to the 

extent consistent with the Wilderness Act’s direction to maintain wilderness character.

Introduction

The Forest Service has developed this needs assessment to determine the types of commercial 

outfitter/guide activities that could take place in the West Chichagof - Yakobi Wilderness (WCYW). A 

needs assessment is a methodology for determining if there is a ‘need’ for private enterprise to assist the 

agency in providing access, services and/or other assistance for the recreating public to enjoy National 

Forest wilderness areas. This document is tiered to the Tongass Land and Resource Management Plan 

(“Forest Plan”; USDA Forest Service 2008b) and the Determination of Need and Extent of Commercial 

- 3 - 
Uses within Wilderness Areas on the Tongass National Forest (USDA Forest Service 2007). Relevant 

management direction is provided in Appendix A. 

This needs assessment is part of a sequential process of evaluating commercial recreation use on National 

Forest System lands within wilderness. It only pertains to commercial recreation activities and not to 

other commercial or non-commercial uses. Other aspects of administering commercial recreation use 

outside the scope, but tiered to this assessment include: 

Visitor capacity is the amount of recreational use (both commercial and non-commercial) an area 

can accommodate given the desired natural conditions, visitor experiences, and management 

program. Visitor capacity is an administrative process to identify the reasonable amount of 

recreation opportunities that are consistent with management direction for an area. Once a capacity 

is determined it can be used as a tool to develop a proposed action for allocating commercial 

outfitter and guide use and environmental analysis.

Environmental analysis document per National Environmental Policy Act (NEPA) analyzes a 

proposed commercial outfitter and guide allocation of the overall recreation capacity and will 

establish mitigation measures that balance use with protection of the National Forest resource. 

These public planning processes inform decision makers of choices among alternative courses of 

action based upon resource capability and public input.

A prospectus may be necessary to implement NEPA decisions when demand for commercially 

guided recreation opportunities exceeds the available capacity. A prospectus requires commercial 

operators to submit bid applications that meet specific criteria. The Authorized Officer allocates 

commercial use to businesses that best meet the criteria.

Special uses permits authorize individual outfitter and guides within the determined allocation and 

according to established mitigation measures.

The need for commercial services is determined by assessing the ability of activities to be compatible 

with the Wilderness Act of 1964 (“Wilderness Act”). A determination of need may be found where 

activities fulfill the purposes of the Wilderness Act and are compatible with preserving wilderness 

character. Market-generated demand for conducting outfitter and guide activities does not, by itself, 

constitute a need for commercial services. Identification of need also considers how an outfitter and guide 

operation can contribute to meeting Forest Plan management objectives. 

This needs assessment:

1. Determines the need for various activities of commercial outfitter and guiding services based on

fulfilling the purposes of the Wilderness Act and compatibility with preserving wilderness character

within the WCYW.

2. Is an internal analysis.

3. Does not analyze or mitigate potential environmental impacts from commercial outfitting and guiding

activities.

4. Does not determine, establish, allocate or authorize commercial outfitter and guide services.

Outfitter/guides can serve as important partners for the Forest Service. In particular, they can provide 

wilderness awareness and leave no trace education for visitors that may not be reached by other 

educational efforts. Outfitter/guides can also assist with monitoring activities, such as reporting invasive 

plants and illegal activities; these activities help the Forest Service achieve a higher level of wilderness 

stewardship. Existing outfitter/ guide activities occurring in WCYW are authorized under the Shoreline 

Outfitter/Guide Record of Decision and Final Environmental Impact Statement (USDA Forest Service 

2004). This decision is currently under review. 

- 4 - 
West Chichagof - Yakobi Wilderness 

Area Description

The West Chichagof-Yakobi Wilderness (WCYW) includes 265,286 acres of coastal temperate rainforest, 

bounded to the west by the Gulf of Alaska (Figure 1). The wilderness area spans approximately 60 miles 

of coastline and includes hundreds of smaller islands in close proximity to Chichagof and Yakobi Islands. 

The communities of Sitka and Hoonah are each about 30 miles distant from their nearest respective access 

to the wilderness. The village of Pelican lies only a short distance from the WCYW boundary. 

WCYW consists of numerous sheltered bays and a wild outer coast. Western hemlock and Sitka spruce 

forests cover approximately one-third of the WCYW, with muskeg, alpine, and estuarine vegetation 

making up the rest. Sitka black-tailed deer are common and brown bears are frequently sighted, along 

with an abundance of smaller furbearing animals. Migratory waterfowl frequent WCYW in large numbers 

and marine mammals, including sea otters, sea lions, and seals, can be seen. 

Long before the Russians came, Tlingit Indians began utilizing this area for its rich natural resources. 

Centuries of people’s close relationship to the land have left behind mining cabins and equipment, 

remnants of fox farms, small communities, and Tlingit village sites. Remnants of past and current human 

presence include several mine adits, cabins, fish weirs, and trails. 

The WCYW is remote and difficult to access and the wilderness character of the area is largely intact. 

There are concerns about the impacts of motorized transport, particularly floatplanes and motorized boats, 

in some areas of the WCYW. The Alaska National Interest Lands Conservation Act (ANILCA) allows for 

the use of motorized boats and planes to access WCYW, but does not discuss their use for commercial 

outfitting and guiding purposes. Ultimately, the Forest Service must ensure that the area is administered 

for the use and enjoyment of the American people leaving it unimpaired for future use and enjoyment as 

wilderness while protecting the area and preserving its wilderness character (Wilderness Act of 1964, 

Section 2(a)).

- 5 - 
Figure F4-1. West Chichagof-Yakobi Wilderness vicinity map. 

Commercial Visitor Use

Like many of the wilderness areas on the Tongass National Forest, WCYW is primarily accessed by float 

plane or boat. Weather, marine conditions, and terrain make this remote area difficult to access. 

- 6 - 
Thirty outfitter/guides were permitted and providing visitor services in the WCYW between 2008 and 

2012; their activities provide services for forest visitors that are unfamiliar with Southeast Alaska’s 

wilderness. Authorized outfitted and guided activities include big game hunting for brown bear and deer, 

remote setting nature tours (including hiking, beach use, hot spring use, and wildlife viewing), camping 

(including some overnight use at Greentop public recreation cabin), freshwater fishing, and outfitting. 

Outfitter/guides are required to submit use reports annually that identify the use location, type of use, 

number of clients, number of groups, and length of stay at each location. From this information, the 

number of service days used at each location is calculated. A service day is defined as a day, or any part 

of a day, on National Forest System lands for which an outfitter/guide provides goods or services, 

including transportation, to a client. Actual use reports provide an effective mechanism to track and 

monitor outfitter and guide use in wilderness. Table 1 shows the type and amount of outfitter/guide use 

that occurred in WCYW between 2008 and 2012. 

Table F4-1. Amount of service days1 of outfitter and guide activities occurring in WCYW, 

2008-2012. 

Activity 2008 2009 2010 2011 2012 Average 

Annual Use 

2008-2012

Big Game Hunting 

– 

Brown Bear 

155 125 143 115 143 136

Big Game Hunting 

– 

Deer

0 0 0 13 0 3

Remote Setting 

Nature Tours 

(including hiking, 

hot spring, 

wildlife viewing, 

and beach use)

157 112 43 78 27 83

Freshwater 

Fishing

114 48 22 29 44 51

Camping 20 33 50 88 50 48

Outfitting 21 0 0 0 0 4

1 A service day is defined as a day, or any part of a day, on National Forest 

System lands for which an outfitter or guide provides goods or services, 

including transportation, to a client.

Almost half of the guided use occurring in WCYW involves day use brown bear hunting accessed via 

motorized boat. Guided brown bear hunters typically stay on a live-aboard boat during their hunt. In 

spring, they scan the shoreline beaches from their vessel before beginning their stalk. More use occurs in 

the uplands during the fall season when hunters can more easily travel by foot along streams. One brown 

bear hunting guide has reported occasional overnight use at Rust Lake. 

Most guided deer hunting occurs in association with guided brown bear hunts. Clients are given the 

option of including a deer hunt as part of a package, with the target species still being brown bear. In 

recent years, however, there has been an increased interest in guided deer-only hunting. 

- 7 - 
The second most popular outfitter/guide activity occurring in WCYW between 2008 and 2012 was remote 

setting nature tours (including hiking, hot spring, wildlife viewing, and beach use). White Sulphur 

Springs is a popular location for guided visitors. Guides have also reported remote setting nature tour use 

at Takanis Lake, Green Top, Goulding Lake, Didrickson Bay, and Dry Pass Trails. 

Guided camping (including overnight use at public recreation cabins) in WCYW has primarily involved 

visitors on kayak-based excursions and the majority of this use has occurred along the shoreline. Some 

overnight use has been reported at Green Top public recreation cabin; however other wilderness cabins 

are not currently available for commercial use. It is anticipated that lake visits from unguided visitors will 

continue to decrease due to transportation costs. 

There are 13 businesses permitted and providing guided freshwater fishing in WCYW; not all service 

days are being utilized. Ford Arm is the most frequently fished location primarily during the steelhead run 

in April-May. 

 Outfitting has occurred infrequently in the WCYW since 2008. One operator has expressed an interest in 

providing transportation and outfitting services to visitors, but there has not been a large demand for this 

type of use. 

Determination of Need for Commercial Services – Assumptions and 

Evaluation Criteria

Assumptions

The following are assumptions made to aid in the assessment of the need for outfitter/guide operations: 

• Some people would not visit the WCYW without an outfitter or guide because they lack the

skills, knowledge, equipment, or ability to do so on their own, or they have safety concerns.

• There will be a continued demand for special use permits to conduct outfitter and guide

operations in the WCYW. Access points and use locations are generally limited to safe harbors

and accessible beaches. Increased demand and use levels at popular locations are issues to

consider.

• Overall visitor use is expected to remain at current levels or continue to increase (Forest Plan).

There may also be shifts in use patterns (timing and location) and user types (hikers, backpackers,

campers, day users, etc.).

• Visitor conflicts have the potential to increase if overall use increases. Conflicts are already

occurring in some areas on the district, particularly between guided bear hunters and visitors

participating in other types of activities (e.g. freshwater fishing, remote setting nature tours).

Guided and unguided groups tend to participate in similar activities at similar locations.

Evaluation Criteria

The following criteria were used to determine the public need for commercial outfitter and guide services 

in WCYW:

• Wilderness Dependence

• Potential Impacts to Wilderness Character

• Knowledge, Skills, and Equipment Needed

• Visitor Safety

• Outfitter and Guide Demand and Utilization

• Public Purpose & Management Objectives

- 8 - 
Wilderness Dependence

The Forest Plan directs managers to “Avoid authorizing uses that are not dependent upon Wilderness 

resources or uses for which reasonable alternative locations exist outside of Wilderness” (USDA Forest 

Service 2008b, p.3-12). Determination of need is based on the extent to which the proposed service can or 

cannot be offered on non-wilderness National Forest System (NFS) lands or non-NFS lands, including 

private or other public lands. Wilderness dependence may also be considered for 1) trips in which solitude 

or primitive and unconfined recreation are the central components of the experience; and 2) visits to 

ecosystems, geological features, or physical resources found predominantly in wilderness for recreational, 

scientific, or educational purposes.

This needs assessment is one part of a sequential process of evaluating commercial recreation use on NFS 

lands within wilderness. Applications for outfitter and guide use in WCYW must include adequate 

justification for why the proposed activity requires the use of wilderness. 

Potential Impacts to Wilderness Character 

Determination of need is based on the extent to which outfitter and guide activities have the potential to 

degrade or improve wilderness character. The Wilderness Act specifies that “each agency administering 

any area designated as wilderness shall be responsible for preserving the wilderness character of the area” 

(Section 4(b)). The wilderness character of WCYW is largely intact due to the area’s remoteness, 

challenging terrain, and limited means of access. There are, however, some areas where wilderness 

character is affected by recreational use. Section 2(c) of the Wilderness Act defined the qualities of 

wilderness character that managers shall try to preserve, which include the following: 

• Untrammeled – The wilderness is essentially unhindered and free from modern human control

or manipulation. This quality describes the degree to which management actions “hinder” or

“control” the land and natural processes. For example, the wilderness area has remained free of

management activities that have altered natural systems, such as dams or regulations that govern

visitor activities. Outfitter and guide activities generally do not affect the untrammeled quality of

wilderness character.

• Natural - Wilderness ecological and evolutionary systems are substantially free from the effects

of modern civilization. This quality describes the ecological effects of human activities on

vegetation, soils, air quality, or other physical and biological components of wilderness. Outfitter

and guide activities have the potential to impact the natural qualities of wilderness character.

The natural quality of wilderness character in WCYW is largely unaffected by past and present

human activity; however there are some noted instances of affect. Red squirrels, marten, beaver,

and non-native fish species have been introduced. Rainbow Trout were stocked in Elfendahl,

Goulding, and Suloia Lakes. Thirteen non-native plant species, comprising 2.5 acres, have been

documented. Forest Service employees have documented soil and vegetation impacts at a

campsite on an unnamed lake at 920’ elevation as well as campsites near Ford Arm within

WCYW.

• Undeveloped - Wilderness retains its primeval character and influence and has minimal

evidence of modern human occupation or modification. This quality describes the effects of

structures, habitations, or other evidence of human presence or occupation.

The past and current presence of humans is evident in WCYW; several mine adits, permitted

cabins, and private inholdings exist. Developments include an abandoned cabin at Klag Ballard

Claim, two fish weirs (Ford Arm and Klag Bay), two isolated cabins (Klag and Lake Anna), and

two agricultural residences at Greentop. There are also several old mine sites at Cook, Branson,

Herbert Graves, Falcon, and Cobol and three large-scale developments, including Boomer Mine

Road, Sisters Lake Powerhouse, and Chichagof Mine (inholding). Unauthorized structures have

- 9 - 
occurred at Lower Goon Dip Lake, Lake Elfendahl, and Ford Arm, which have a localized impact 

on the undeveloped quality of wilderness character. 

The Forest Service maintains four public recreation cabins in WCYW, including White Sulphur 

Cabin and Bathhouse, Greentop, Goulding Lake, and Suloia Lake Cabins. Impacts at cabins and 

dispersed campsites include tree damage, litter, fire rings and duff fires, and social trails. 

Outfitters and guides are required to practice Leave No Trace to minimize their impacts. 

In general, there is less evidence of human occupation or modification as one travels inland from 

the shoreline zone. Outfitter and guide activities that require the use of temporary or permanent 

structures, or create noticeable impacts on the ground, have the potential to further impact the 

undeveloped quality of wilderness character in WCYW. 

• Outstanding opportunities for solitude or a primitive and unconfined type of recreation.

Wilderness provides outstanding opportunities for people to experience natural sights and

sounds, solitude, freedom, risk, and the physical and emotional challenges of self-discovery and

self-reliance.

Noise associated with motorized transport (e.g. motorized boats and float planes) has the potential

to diminish wilderness character by reducing opportunities for solitude. While some motorized

activities occur in the air and on the marine waters adjacent to WCYW, and are outside of Forest

Service jurisdiction, other activities (e.g. floatplane landings on lakes and shoreline excursions

associated with motorized transport) are within Forest Service jurisdiction and require a special

use authorization.

Surveys undertaken at the lakes in WCYW between 2003 and 2008 indicate that opportunities for

solitude are outstanding at most lakes. There is, however, limited useable space on most lakes.

For other areas, conflicts may occur between visitors, particularly during steelhead fishing season

(April - May) and the spring and fall bear hunting seasons.

In general, outstanding opportunities for solitude exist throughout WCYW, particularly in the

interior portions of the larger islands and Chichagof Island. These areas receive fewer visitors due

to the lack of facilities and difficult lake landings and are away from the primary marine travel

routes and popular commercial fishing anchorages.

• Other Features of Value. This quality pertains to distinct features fundamental to the wilderness

character that are not contained within the other qualities. This aspect is based on the last clause

of Section 2(c) in the Wilderness Act, that a wilderness “may also contain ecological, geological,

or other features of scientific, educational, scenic, or historical value.” This fifth quality is unique

to an individual wilderness based on the features that are inside that wilderness. These features

typically occur only in specific locations within a wilderness and include cultural resources,

historical sites, paleontological sites, or any feature not in one of the other four qualities that has

scientific, educational, scenic, or historical value. The following unique qualities are associated

with WCYW:

• Brown Bear - Admiralty, Baranof, and Chichagof Islands together are considered unique

due to the singular large predator (brown bear) dominating these landscapes.

• White Sulphur Springs offers a unique soaking experience on the outer pacific coast

that dates back to the early 1900s. This site has been determined eligible for the National

Register of Historic Places for Traditional and Cultural Values based on its importance to

the communities that have historically used the site. Four generations of residents from

the communities of Pelican, Elfin Cove, and Gustavus have used the site for community

and family gatherings; the commercial fishing fleet has used the site for decades to

celebrate season opening and closings, and for bathing and washing.

- 10 - 
• Historic and Pre-Historic Values - Since pre-historic times the lands within the WCYW

have supported a broad range of human use, development and occupancy. Thousands of

years ago West Chichagof became an area of seasonal habitation by local native peoples.

Little is known about the prehistoric use of the present-day wilderness. There are a few

documented prehistoric sites, but surveys have been very limited. Later, Russians and

Americans arrived. Despite the continual presence by humans, the wilderness character

of the area remained virtually uncompromised until the late 1890s when extensive

mineral prospecting began in southeast Alaska. From then until the late 1950s the outer

coast supported numerous small settlements associated with mining, fur farms, fishing

and services in support of these activities. Since 1950, however, most of these activities

have been discontinued and many of the sites are being reclaimed by nature.

• Subsistence Use - Gathering wild food and other items has been an integral part of the

way of life in southeast Alaska for thousands of years. At one time or another, the entire

coastal zone of the WCYW has been used for subsistence gathering. Traditionally,

Hoonah residents have used the Cape Bingham area and the mouth of Lisianski Strait for

harvesting sea mammals. Waterfowl and game were harvested around the mouth of

Lisianski Strait. Waterfowl was harvested in the White Sulphur area. Pelican residents

used Stag Bay, Lisianski Inlet and Lisianski Strait for the taking of personal-use timber

and in the early part of the century; mining operations in and around Klag Bay resulted in

subsistence use of that area as well. Today, residents of Hoonah, Pelican, Elfin Cove, and

Gustavus still depend a great deal on subsistence gathering activities. In general, the

entire area is used for the harvest of seal and sea otter by groups exempt from the Marine

Mammal Protection Act; Lisianski Inlet, Lisianski Strait and Stag Bay are used for

harvesting game animals, fish and furbearers. A variety of subsistence activities occur in

the Hoktaheen, Takanis and Surge Bay areas on Yakobi Island and the Klag Bay, Ford

Arm and Leo's Anchorage areas on Chichagof Island.

• Early roots of environmentalism in Alaska - The Sitka Conservation Society, an

environmental/community advocacy organization based in Sitka, was formed in 1967

around the establishment of the West Chichagof-Yakobi Wilderness. The special

qualities of this place inspired a group of Sitka residents to develop the first citizens’

proposal for establishment of a wilderness area in Alaska. This initial effort resulted in

the designation of West Chichagof-Yakobi Wilderness under ANILCA in 1980.

In general, outstanding opportunities exist in WCYW for hunting and viewing brown bear, for exploring 

the history of the area at numerous historic sites, for subsistence gathering, and for experiencing the 

special qualities that led to the proposal and designation of the area as wilderness. Recent improvements 

to White Sulphur Springs bathhouse and cabin will ensure that another generation of visitors can continue 

their traditions associated with this site. However, the other historic sites that exist across the WCYW 

landscape are slowly being reclaimed by nature and will eventually cease to exist. With the exception of 

White Sulphur Springs, the Forest Service does not have plans to restore or maintain any of the features 

associated with the other existing historic sites. Thus, the history that is documented will be retained, but 

the features themselves have a limited lifespan and will eventually fade. 

Knowledge, Skills, and Equipment Required

Determination of need is based on the degree to which outfitter and guide services are needed by the 

public because 1) the specific skills required for activities appropriate to the area require substantial time 

and/or talent to learn; 2) participating in the activity requires acquisition and use of expensive, specialized 

equipment for which the public could not, or ordinarily would not, expend the time and money; and 3) the 

skills, knowledge, and equipment required are so unique that the use of an outfitter or guide is almost a 

prerequisite if area visitors are to have the opportunity to participate safely, while still achieving a level of 

- 11 - 
self-reliance and challenge in the activity. Outfitters and guides possess knowledge about the local area 

and wilderness resource that may be required to safely access the area and minimize resource damage and 

visitor conflicts. This knowledge may include knowing where, and by what method, to best access and 

travel through an area. 

Visitor Safety

Determination of need is based on the degree to which outfitter and guide services are needed by the 

public because of the special skills, knowledge, and equipment needed for a reasonable level of visitor 

safety. Without guide assistance, members of the public and visitors to the area may seriously endanger 

their health or lives, or would not visit the wilderness area due to safety concerns. Outfitter and guide 

services should not diminish other wilderness visitors’ opportunities to experience a degree of challenge 

and risk, and/or sense of self-reliance. 

Outfitter and Guide Demand and Utilization

Determination of need is based on the amount of demand that exists for an outfitter and guide activity and 

the extent to which the activity is already authorized, and the amount of use currently occurring. Marketgenerated demand for conducting outfitter and guide activities does not, by itself, constitute a need for 

commercial services. However, the determination of public need for a service is informed by examining 

current and past use trends. 

Public Purposes / Management Objectives

The Wilderness Act specifies that “Wilderness areas shall be devoted to the public purposes of 

recreational, scenic, scientific, educational, conservation, and historical use” (Section 4(b)). 

Determination of need is based on the extent to which guide services help fulfill these public purposes of 

wilderness. Determination of need is also based on the degree to which outfitters and guides help the 

Forest Service meet management objectives to 1) provide opportunities for public use, enjoyment, and 

understanding of the wilderness through experiences that depend upon a wilderness setting and are 

consistent with management of the area as wilderness, and 2) provide opportunities for special 

populations, including persons with disabilities and the elderly, to access certain areas and participate in 

recreational and educational activities. Guides can serve as important partners for the Forest Service by 

providing wilderness awareness education and training in outdoor skills and ethics. Consideration will 

also be given to the compatibility of commercial use with use by the general public. 

Determination of Need for Commercial Services by Activity

Activities Considered

A review of past and current outfitter and guide use in the WCYW provided a starting point for this needs 

assessment. Based on past proposals and actual use, the following commercial outfitter and guide 

activities were considered:

• Big Game Hunting for Brown Bear

• Big Game Hunting for Deer

• Camping (including overnight use of public recreation cabins)

• Floatplane Landing Tours

• Freshwater Fishing

• Remote Setting Nature Tours

This assessment may be revised in the future as recreation use patterns change and demands for new 

outfitter/guide services are identified. 

- 12 - 
Big Game Hunting – Brown Bear 

Brown bear hunting includes day use and overnight activities in the wilderness. Activities incidental to 

the primary brown bear hunt may involve camping, remote setting nature tour activities, freshwater 

fishing, or hunting for lower value game and waterfowl species. 

Table F4-2. Brown Bear Hunting needs. 

Evaluation Criteria Evaluation of Need

Wilderness 

Dependence

Guide Use Areas (GUAs) 04-13, 04-14, and 04-15 encompass the WCYW. GUAs 04-

13 and 04-15 have large tracts of non-wilderness NFS lands with suitable bear 

habitat and hunting opportunities. GUA 04-14 is entirely within wilderness. The 

closest private lands to WCYW are located in the town of Pelican and at Soapstone 

Cove. A limited amount of private land (Shee Atika Incorporated) may be available 

in Katlian Bay (north of Sitka) for bear hunting. Permission would need to be 

secured from the landowner. 

Wilderness Character The majority of guided hunting in WCYW and surrounding areas on the Tongass 

National Forest is boat-based and results in minimal impacts to vegetation, soil, 

and water resources. Guided groups typically stay aboard a boat and hike up 

streams and very little use occurs in the uplands. The Alaska Department of Fish 

and Game (ADF&G) provides recommendations, population estimates, and 

historical harvest data to help the Forest Service determine the number of guided 

hunts an area can sustain. Guided hunting groups have the potential to impact the 

undeveloped quality of wilderness if tent platforms are constructed or remain in 

place when not in use. Guided groups also have the potential to impact 

opportunities for solitude, particularly if access is by motorized boat or floatplane, 

and use occurs in popular areas. Conflicts have been reported on other parts of the 

district between guided bear hunting groups and other permitted users, such as 

freshwater fishing and remote setting nature tour groups. Conflicts with unguided 

visitors are less common as brown bear hunting is not a popular unguided activity.

Skills, Equipment, and 

Knowledge Required 

Visitors primarily access the WCYW using motorized boats or float planes. 

Outfitters and guides can provide the skills, equipment, and knowledge required to 

safely access and enjoy the wilderness. ADF&G requires non-resident brown bear 

hunters to be accompanied by a registered guide or a relative within the second 

degree of kin. The knowledge and skills required to identify male bears and 

properly care for the animal carcass in accordance with State law are considered to 

be beyond the average person’s abilities.

Visitor Safety Southeast Alaska’s weather conditions and tidal fluctuations can be extreme 

throughout the year. Exposure to wind and cold weather poses a threat to visitor 

safety. Wildlife encounters, particularly with brown bear, also pose a risk to safety. 

Guides know how to track and retrieve animals, carry radios and/or satellite 

phones for communication, and carry back-up rifles in case of emergency.

Outfitter and Guide 

Demand and Utilization

There is consistently high demand for guided brown bear services in WCYW. 

Between 2008 and 2012, nearly half of the guided use in WCYW was for brown 

bear hunting. Most authorizations are being fully utilized by existing guides. There 

are also several prospective applicants should more guided brown bear hunts 

become available. Most guides are booked years in advance for these hunts.

Public Purposes & 

Special Management 

Objectives

Guided brown bear hunting contributes to the recreational purpose of wilderness. 

Guides can also help the ADF&G male to female harvest ratio objectives and ensure 

that hunters care for and process carcasses in accordance with State law. Guide 

hunt records also help track harvest locations and success rates, contributing to 

better management of bear populations.

Outfitter/guides provide access to brown bear hunting opportunities in WCYW that would otherwise be 

unavailable to many members of the visiting public because of the high level of knowledge, skills, and 

- 13 - 
equipment needed to safely conduct a remote hunt. Outfitters and guides also help the Forest Service meet 

special management objectives for dispersing impacts related to nonresident harvest. This activity 

contributes to the recreational purpose of wilderness and has little resource concerns. These factors, along 

with the State of Alaska’s requirement for non-resident hunters to be accompanied by a licensed guide, 

indicate there is a need for outfitter/guide brown bear hunting services in WCYW. Guides operating in 

WCYW will be required to educate clients about low-impact skills to minimize impacts to the natural and 

undeveloped qualities of wilderness character. 

Big Game Hunting – Deer 

Deer hunting includes day use and overnight activities in the wilderness. Activities incidental to the 

primary deer hunt may involve camping, remote setting nature tour activities, freshwater fishing, or 

hunting for lower value game and waterfowl species. 

 Table F4-3. Deer Hunting needs. 

Evaluation Criteria Evaluation of Need

Wilderness 

Dependence

Guide Use Areas (GUAs) 04-13, 04-14, and 04-15 encompass the WCYW. GUAs 04-

13 and 04-15 have large tracts of non-wilderness NFS lands with suitable deer 

habitat and hunting opportunities. GUA 04-14 is entirely within wilderness. The 

closest private lands to WCYW are located in the town of Pelican and at Soapstone 

Cove. A limited amount of private land (Shee Atika Incorporated) may be available 

in Katlian Bay (north of Sitka) for deer hunting. Permission would need to be 

secured from the landowner. 

Wilderness Character The majority of guided hunting in WCYW and surrounding areas on the Tongass 

National Forest is boat-based and results in minimal impacts to vegetation, soil, 

and water resources. Guided groups typically stay aboard a boat and hike up 

streams and very little use occurs in the uplands. ADF&G provides 

recommendations, population estimates, and historical harvest data to help the 

Forest Service determine the number of guided hunts an area can sustain. Guided 

hunting groups have the potential to impact the undeveloped quality of wilderness 

if tent platforms are constructed or remain in place when not in use. Guided groups 

also have the potential to impact opportunities for solitude, particularly if access is 

by motorized boat or floatplane, and use occurs in popular areas. Currently, 

conflicts are uncommon with guided deer hunters and non-guided or subsistence 

hunters due to the limited amount of use that has occurred. However, subsistence 

use has historically occurred in this wilderness area and is identified as an Other 

Feature of Value. If demand increases, consideration will be needed for 

subsistence users.

Skills, Equipment, and 

Knowledge Required 

Visitors primarily access the WCYW using motorized boats or float planes. 

Outfitters and guides can provide the skills, equipment, and knowledge required to 

safely access and enjoy the wilderness. A guide can ensure that State regulations 

and ethical hunting procedures are followed. Guides are also knowledgeable about 

deer behavior and where conflicts with unguided visitors may occur. There is no 

State requirement for a registered guide for deer hunting.

Visitor Safety Southeast Alaska’s weather conditions and tidal fluctuations can be extreme 

throughout the year. Exposure to wind and cold weather poses a threat to visitor 

safety. Wildlife encounters, particularly with brown bear, also pose a risk to safety. 

There have been documented incidents of deer hunters being attacked by brown 

bear. Guides carry radios and/or satellite phones for communication and back-up 

rifles in case of emergency. 

Outfitter and Guide 

Demand and Utilization

Between 2008 and 2012, there was a low level of demand for guided deer hunting. 

Most guided deer hunting occurs as incidental take to a bear hunt, or as part of 

combination hunt for bear and deer. Recently, there has been an increased demand 

for adding deer-only hunts to existing big game hunting permits. 

Public Purposes & Guided deer hunting contributes to the recreational purpose of wilderness. Guide 

- 14 - 
Special Management 

Objectives

hunt records help track harvest locations and success rates, contributing to better 

management of deer populations. Guides can also teach clients about low-impact 

camping and hiking skills.

Outfitter/guides provide access to deer hunting opportunities in WCYW that would otherwise be 

unavailable to many members of the general public because of the high level of knowledge, skills, and 

equipment needed to safely conduct a remote hunt. Outfitters and guides also help the Forest Service meet 

special management objectives for dispersing impacts related to nonresident harvest. This activity 

contributes to the recreational purpose of wilderness and results in limited impacts to Forest resources, 

including wilderness character. These factors indicate there is a need for outfitter/guide deer hunting 

services in WCWY. 

Camping (including overnight use of public recreation cabins)

Camping is defined as overnight use within the wilderness. Daytime activities may involve boating or 

kayaking on marine waters or remote setting nature tours, hunting, or freshwater fishing within the 

wilderness. This use depends on sites amenable to camping such as level ground, accessible beach, 

availability of water, secure boat anchorage or storage, a food cache site, minimal signs of use by bears, 

and so on. 

Table F4-4. Camping needs. 

Evaluation Criteria Evaluation of Need

Wilderness 

Dependence

Opportunities for guided camping exist in the non-wilderness portion of the Sitka 

Ranger District and surrounding areas of the Tongass National Forest. Wilderness, 

however, provides the remote wild land setting desired for this type of activity. 

Wilderness also provides an opportunity for guided visitors to practice Leave No 

Trace camping skills and learn about outdoor ethics. Camping opportunities are 

limited on non-NFS lands; some opportunities may exist at Katlian Bay (Shee Atika 

Incorporated), and nearby Magoun Islands, Sea Lion Cove, and Big Bear Baby Bear 

State Parks. 

Wilderness Character Guided camping generally occurs on the beaches along the shoreline of WCYW and 

results in minimal impacts to vegetation, soil, and water resources. There are some

locations where impacts to vegetation and soil are noticeable. There is also a 

potential for guided groups to impact opportunities for solitude in the wilderness, 

particularly if the groups are large or use is authorized in popular locations (e.g., 

White Sulphur Springs). Many of the lakes in WCYW are small and can only 

accommodate one group for camping. Motorized boat traffic along adjacent 

waterways also has the potential to reduce opportunities for solitude. Guided 

camping tours do not affect the untrammeled and undeveloped qualities of 

wilderness character. Guided camping may increase the size of existing campsite 

boundaries. Firewood collection for campfires could occur, resulting in “human 

browse lines” or stumps. Stipulations for waste disposal and use of fire pans would 

have to be added to permits to ensure degradation of areas did not occur.

Skills, Equipment, and 

Knowledge Required 

Camping visitors primarily access the WCYW using kayaks, motorized boats or 

float planes, including charter services. Outfitters may also provide camping 

equipment that visitors do not have. Outfitters and guides can provide the skills, 

equipment, and knowledge required to safely access and enjoy the wilderness. 

Guides also provide the skills, equipment, and knowledge needed to minimize 

impacts from overnight visitors. Camping (including stays at remote wilderness 

public use cabins) involves skills that embrace traditional techniques and include 

elements of risk and challenge, especially for those new to the activity. It 

encourages self-reliance and helps strengthen independent decision-making. 

- 15 - 
Visitor Safety Southeast Alaska’s weather conditions and tidal fluctuations can be extreme 

throughout the year. Exposure to wind and cold weather poses a threat to visitor 

safety, however there are parts of WCYW that provide more protected waters and 

suitable locations for sheltering from the weather. Wildlife encounters also pose a 

risk to safety. Outfitters and guides may provide communication with rescue 

services in the event of an emergency. 

Outfitter and Guide 

Demand and Utilization

There is demand for guided camping services in the WCYW. Between 2008 and 

2012, an average of 48 service days annually was reported for this guided activity. 

The shoreline areas in this wilderness provide desirable recreation settings for this 

type of activity. There have been no commercial use requests for fly-in non-hunting 

related camping, with the exception of cabin camping, at any lakes in WCWY.

Public Purposes & 

Special Management 

Objectives

Guided camping tours provide an opportunity for the visiting public to safely 

access and enjoy the WCYW for recreational pursuits. Multiple day experiences 

allow visitors to forge deep connections with nature. Outfitters and guides 

providing camping tours emphasize Leave No Trace skills and outdoor ethics. 

Campers often seek a wild land setting and this activity is consistent with the 

management of the area as wilderness. Forest Plan direction for public use cabins 

located in wilderness is to maintain them at present or improved condition. 

However, high costs of maintenance for low-use cabins are becoming prohibitive. 

An opportunity exists for partnerships with guides to perform deferred 

maintenance on low-use cabins or provide firewood. Guides who pursue this 

activity could educate visitors on the use of primitive tools as well as the enabling 

legislation, which allows for these structures in wilderness. 

In summary, guided camping generally occurs on the beaches and along the shoreline of WCYW and 

results in minimal impacts to vegetation, soil, and water resources. Wilderness provides an opportunity 

for guided visitors to practice traditional skills, learn about outdoor ethics, and forge deep connections 

with nature. Backcountry camping experiences depend on a wild land setting and are consistent with 

management of the area as wilderness. Outfitters and guides can provide area visitors with the skills, 

equipment, and knowledge required to safely access and enjoy the wilderness. There is a need for 

outfitter/guide camping services in WCYW. 

There is a potential for guided groups to impact opportunities for solitude in the wilderness, particularly if 

the groups are large, use is authorized in popular locations (e.g., White Sulphur Springs), and access is via 

motorized transport. Group size will be limited to twelve in non-cabin locations and six to eight persons 

at cabins (depending on cabin capacity). Permit stipulations will be designed to reduce potential conflicts 

with unguided visitors. Preference will be given to operators that access the wilderness using nonmotorized transport, that promote Leave No Trace and outdoor ethics, and educate their clients about 

wilderness values.

Floatplane Landing Tours 

A floatplane landing tour is defined as a day-use activity that predominantly involves viewing natural 

features by air and landing once or multiple times within the wilderness and returning back to its point of 

origin. Visitors typically spend little time on land at each stop. Floatplane landing tours do not include 

authorized point-to-point floatplane transport used as an ancillary service to another commercial service 

for activities such as remote setting nature tours, hunting, fishing, or camping (including public use 

cabins).

Table F4-5. Floatplane Landing needs. 

Evaluation Criteria Evaluation of Need

Wilderness 

Dependence

Floatplanes are a common and allowed method of transport for recreation use on 

the Tongass National Forest. However, the authorization of floatplane landing 

tours on the Tongass National Forest is limited and has not been authorized within 

the WCYW. Misty Fiords National Monument provides a high number of service 

- 16 - 
days for operators with lake landings. There are also several air taxi companies 

who provide this service without lake landings. In addition, several lakes exist 

outside of wilderness that offer sightseeing in a lake environment, for example, 

Rosenburg, Cold Storage, and Hogan Lakes.

Wilderness Character This activity is entirely dependent on the use of floatplanes. ANILCA Special Access 

provisions (Section 1110(a)) specifically allow for the continued use of airplanes 

for traditional activities and travel to and from villages and homesites. Recreation 

activities, such as sightseeing, are considered “traditional” as defined in Forest 

Service Manual 2326.1(6) (USDA Forest Service 2008a). As such, the presence of 

floatplanes in WCYW is an accepted method of access and does not constitute a 

degradation of the undeveloped quality of wilderness character. 

However, the frequency and duration of floatplane use can affect outstanding 

opportunities for solitude or primitive and unconfined recreation. Repeated 

landings at locations within wilderness by floatplane landing tour activities are not 

compatible with preserving these outstanding opportunities. The higher incidence 

of floatplane flights and landings that are associated with floatplane landing tours 

degrades the opportunities for those visitors seeking to experience the natural 

sounds of the wilderness and primitive recreation. 

Skills, Equipment, and 

Knowledge Required 

Floatplane landing tours typically do not require a high degree of specialized skill, 

equipment or challenge for the forest visitor. Visitors typically step off the plane 

and explore the nearby area on foot, spending a short amount of time in the 

wilderness before re-boarding the plane. However, this activity does require an 

aircraft and pilot with experience in the challenging flying conditions of southeast 

Alaska. The average person would not have this equipment or skill and commercial 

services are typically needed for this activity.

Visitor Safety Any activity that exposes people to southeast Alaska’s wind, rain, and cold weather 

conditions poses a threat to visitor safety if visitors are unprepared. Wildlife 

encounters may also pose a risk to safety. Hazards that people could encounter 

include brown bears, sudden weather changes, uneven terrain, falls and 

hypothermia. Since the time spent out of the plane is relatively brief and groups 

typically stay close to the landing site, risk of hypothermia and exposure to the 

elements is low. 

Outfitter and Guide 

Demand and Utilization

No outfitter/guides have been authorized for floatplane landing tours in WCYW. 

There have been no commercial use requests for this activity. 

Public Purposes & 

Special Management 

Objectives

This activity predominantly involves viewing natural features from the air and 

landing for only short periods of time within the wilderness. The act of viewing the 

wilderness from an aircraft and spending relatively short periods of time on the 

ground, within the landscape and soundscape, represents an activity 

predominantly inhibited by modern civilization. Although floatplanes are an 

accepted method of access in WCYW, the activity itself does not fulfill the purposes 

of wilderness that strives for invoking opportunities for spirituality and/or allow 

for deep connections with nature. 

In summary, floatplane landing tours do not offer opportunities for self-reliance and challenge to the 

wilderness visitor. This activity is entirely dependent on the use of aircraft to view the wilderness from 

the air with short periods of time on the ground. Although the method of access is allowed, the activity 

itself degrades outstanding opportunities for solitude or primitive types of recreation, and does not 

provide visitors the opportunity for developing deep connections with nature. There is not a need for 

outfitter/guide floatplane landing tour services in WCYW.

- 17 - 
Freshwater Fishing

Freshwater fishing includes both catch-and-take and catch-and-release methods under Alaska sport 

fishing regulations (excludes commercial and subsistence fishing). This use depends on places and times 

where anadromous and resident fish are located. 

Table F4-6. Freshwater Fishing needs. 

Evaluation Criteria Evaluation of Need

Wilderness 

Dependence

Several streams in non-wilderness NFS lands on the Sitka Ranger District and 

surrounding areas of the Tongass National Forest support anadromous fish 

populations and provide excellent freshwater fishing opportunities, including the 

North Arm of Hoonah Sound, Sitkoh, Nakwasina, Salmon Lake, and Lake Eva river 

systems. Opportunities for fishing on non-NFS lands are limited, but include 

Katlian Bay (Shee Atika Incorporated) and possibly State park areas. The nearest 

non-wilderness lakes are located on the east side of Chichagof Island and north of 

Sitka, where fishing opportunities are limited. Catch & release steelhead fishing is a 

guided activity that is desired throughout southeast Alaska and there are a limited 

number of primary steelhead streams available, one of which is in WCYW. 

Wilderness Character The majority of guided freshwater fishing is accessed via motorized boat and 

results in minimal impacts to vegetation, soil, and water resources. Current 

resource concerns at streams include litter, development of “fishing paths,” and 

wildlife displacement. There have been some concerns over habituation of bears in 

site-specific areas on the Sitka district. ADF&G provides sport fishing guidelines 

that help maintain the natural quality of wilderness character through the 

sustainable management of fish populations. Guided groups have the potential to 

impact opportunities for solitude, particularly if the groups are large and use is 

authorized in popular locations (e.g., Ford Arm). Many of the lakes in WCYW are 

small and can only accommodate one or two groups for fishing. Visitor conflicts 

may occur, particularly during steelhead fishing season (April-May). Access via 

motorized boat or floatplane has the potential to impact opportunities for solitude. 

Skills, Equipment, and 

Knowledge Required 

Visitors primarily access the WCYW wilderness using motorized boats or float 

planes. Outfitters and guides can provide the skills, equipment, and knowledge 

required to safely access and enjoy the wilderness. Navigating and route-finding in 

steep, brushy terrain may also be beyond the skill level of many visitors. 

Outfitter/guides can impart knowledge of catch and release techniques, where and 

when the fish runs are occurring, fish identification, and proper disposal methods. 

Visitor Safety Southeast Alaska’s weather conditions and tidal fluctuations can be extreme 

throughout the year. Exposure to wind and cold weather poses a threat to visitor 

safety. Wildlife encounters also pose a risk to safety. 

Outfitter and Guide 

Demand and Utilization

There are several streams and a few lakes that support anadromous fish species in 

the WCYW. Average annual guided use is 51 service days. There are 13 permitted 

guides providing freshwater fishing services in WCYW. Not all service days are 

being utilized. The current level of use for fishing is low depending on the area and 

species. There is potential for conflicts especially in fall and spring during guided 

bear hunts and during times of subsistence fish harvest (June 1 – August 15 at Klag 

Bay and Ford Arm).

Public Purposes & 

Special Management 

Objectives

Guided freshwater fishing contributes to the recreational purpose of wilderness. 

Outfitter/guides promote proper catch and release techniques and an 

understanding of population dynamics in isolated streams and lakes. 

Outfitter/guides are required to turn in freshwater fishing logs to ADF&G; the 

results of these can be used to determine non-resident fishing harvest.

WCYW provides outstanding opportunities for remote freshwater fishing. Fishing is an appropriate use of 

wilderness and outfitter/guides contribute to the recreational purpose of wilderness. Guides can assist 

- 18 - 
visitors by navigating and route-finding in steep, brushy terrain and teach low-impact practices. Guides 

also impart knowledge of catch and release techniques, where the runs are occurring, fish identification 

and proper disposal methods. There is a need for outfitter/guide freshwater fishing services in WCYW. 

Preference will be given to outfitter/guides that promote Leave No Trace and outdoor ethics and educate 

their clients about wilderness values.

Remote Setting Nature Tours 

Remote setting nature tours encompass, but are not limited to, a wide variety of day use activities such as 

hiking, paddling, wildlife viewing, photography, exploring, sightseeing, hot springs soaking, and cultural 

tours. Visitors may spend a few minutes to many hours participating in these activities. Desirable 

attributes for these activities include accessible sections of shoreline, maintained trails and facilities, and 

unique features of geological, ecological, or cultural interest. 

Table F4-7. Remote Setting Nature Tour needs. 

Evaluation Criteria Evaluation of Need

Wilderness 

Dependence

There are opportunities for guided remote setting nature tours (RSNT) on nonwilderness NFS lands on the Sitka Ranger District and surrounding areas of the 

Tongass National Forest. For example, Rosenburg, Cold Storage, and Hogan Lakes

can provide sightseeing and hiking opportunities at a lake environment. There are 

also outstanding hiking opportunities to the north of Sitka at non-wilderness 

locations including Bohemia Basin, Lisianski Trail, Lake Eva, Kruzof Island, Sitkoh, 

and Kook Lake. Guides currently offer tours in all of these areas. RSNT 

opportunities are limited on non-NFS lands; some opportunities exist at Katlian 

Bay (Shee Atika Incorporated), nearby State parks including an outstanding trail to 

Sea Lion Cove. Guides currently offer hikes in some of these non-NFS locations. 

However, wilderness provides the remote, wild land setting often desired for these 

activities. WCYW in particular provides visitors the opportunity to learn about and 

experience the cultural history features and rural Alaskan lifestyle that is unique to 

this wilderness. 

Wilderness Character RSNTs occurring in the WCYW are primarily boat-based and use is generally 

concentrated on beaches and along established trails. It is rare that most visitors 

participating in RSNT travel more than one-half mile from shorelines unless there 

is an established trail. As a result, these activities typically result in minimal 

impacts to vegetation, soil, and water resources. However, potential resource 

concerns include repeated use on unprotected native tread (e.g., muskeg and 

forested wetlands), user-created trails and trail marking (e.g. flagging and rock 

cairns), particularly in areas with interesting features and recreation attractions. 

The potential for vegetative damage and soil erosion exists. There is also a 

potential for outfitted/guided groups to impact opportunities for solitude in the 

wilderness, particularly if the groups are large, use is authorized in popular 

locations, or access is by motorized boat or float plane. Impacts to opportunities 

for solitude and primitive and unconfined recreation will be most noticeable in 

areas where visual screening from vegetation and topography is low. 

Skills, Equipment, and 

Knowledge Required 

Visitors primarily access the WCYW using boats or float planes. Outfitters and 

guides can provide the skills, equipment, and knowledge required to safely access 

and enjoy the wilderness. Equipment for day hiking (e.g. rain gear, footwear, warm 

clothing) can be obtained at relatively inexpensive prices at stores nationwide. Air 

taxi services can drop off and pick up visitors at locations of their choice, but 

without local knowledge of the landscape, it may be difficult for a visitor to identify 

suitable locations for this activity. Outfitters/ guides can provide the skills, 

equipment, and knowledge required to safely access the wilderness.

- 19 - 
Visitor Safety While hiking and beach walking are simple skills, Southeast Alaska’s weather 

conditions and tidal fluctuations can be extreme throughout the year. Exposure to 

wind and cold weather poses a threat to visitor safety if visitors are unprepared. 

Wildlife encounters may also pose a risk to safety. Hazards that people could 

encounter include brown bears, sudden weather changes, steep terrain, falls and 

hypothermia. Risk to safety and the physical and emotional challenges of surviving 

in this environment are high.

Outfitter and Guide 

Demand and Utilization

Fourteen outfitter/guides are currently permitted and providing RSNTs in WCYW. 

Of these, not all service days are being utilized and most of the use is occurring at 

White Sulphur Springs and along the shoreline zone surrounding protected bays 

and beaches. Use of the uplands is low, but operators have expressed an interest in 

providing hiking tours on trails that provide access to the upland portion of the 

wilderness from saltwater, as well as floatplane access to lakes.

Public Purposes & 

Special Management 

Objectives

Guided RSNTs provide an opportunity for the visiting public to safely access and 

enjoy WCYW for recreational pursuits. Outfitters/guides providing RSNTs 

emphasize Leave No Trace skills and outdoor ethics. RSNTs depend on a wild land 

setting and are consistent with management of the area as wilderness. Guides 

authorized to operate in wilderness are required to educate clients about Leave No 

Trace outdoor ethics. For example, a guide could encourage clients to spread out in 

alpine and muskeg areas rather than walk single file. Additionally, an opportunity 

exists for partnerships with guides to perform deferred maintenance on low-use

wilderness trails that are becoming cost-prohibitive to maintain.

Remote setting nature tours depend on a wild land setting and are consistent with management of the area 

as wilderness. There is a potential for guided groups to impact opportunities for solitude in the 

wilderness, particularly if the groups are large, use is authorized in popular locations (e.g., White Sulphur 

Springs), and access is via motorized boat or float plane. Guides can assist visitors by navigating and 

route-finding in steep, brushy terrain and teach low-impact practices. Outfitter/guides provide visitors 

with the skills, equipment, and knowledge required to safely access and enjoy the wilderness while still 

achieving a high level of self-reliance and challenge in the activity. There is a need for outfitter/guide 

remote setting nature tour services in SBW. Preference will be given to outfitter/guides that promote 

Leave No Trace and outdoor ethics, educate their clients about wilderness values, use smaller group sizes, 

and use non-motorized transport. Group size will be limited to twelve and permit stipulations will be 

designed to reduce potential conflicts with unguided visitors as well as minimize impacts to soils and 

vegetation.

Citations

ANILCA, 1980. Alaska National Interest Lands Conservation Act, Public Law 96-487, 96th Congress. 

USDA Forest Service, 2008a. Forest Service Manual, Alaska Region (Region 10), FSM 2300 – 

recreation, wilderness and related resource management, chapter 2320 – wilderness management. 

November 14, 2008. 

USDA Forest Service, 2008b. Tongass National Forest Land Resource and Management Plan. January 

2008. R10-MB-603b. 

USDA Forest Service, 2007. Determination of Need and Extent of Commercial Uses within Wilderness 

Areas on the Tongass National Forest.

USDA Forest Service, 2004. Shoreline Outfitter/Guide Record of Decision and Final Environmental 

Impact Statement. December 2004. R10-MB-519a. 

Wilderness Act, 1964. Public Law 88-577. 19 U.S. C. 1131-1136. 88th Congress. 

- 20 - 
Appendix A. Management Direction

The Wilderness Act of 1964

The Wilderness Act of 1964 states the purpose of wilderness is “to secure for the American people of 

present and future generations the benefits of an enduring resource of wilderness.” Wilderness being an 

area “affected primarily by the forces of nature, with the imprint of man’s work substantially 

unnoticeable;” . . . “has outstanding opportunities for solitude or a primitive unconfined type of 

recreation; . . . and “may also contain ecological, geological, or other feature of scientific, educational, 

scenic, or historical value.” 

The Wilderness Act also describes how wilderness areas are to be used and managed. Management is to 

focus on preserving the wilderness character of the area; and use of the area “shall be devoted to the 

public purposes of recreational, scenic, scientific, education, conservation, and historical uses.” In 

realizing these uses wilderness provides an opportunity for solitude or primitive unconfined types of 

recreation not attainable in settings more man-made, or influenced by humans. 

In accomplishing the purpose of, and uses of wilderness, the Wilderness Act gives some additional 

direction. Specifically, with one notable exception commercial enterprises are prohibited by Section 4(c) 

of the Act. The exception covered in Section 4(d) (6) says; “commercial services may be performed 

within the wilderness area . . . to the extent necessary for activities which are proper for realizing the 

recreation or other wilderness purposes of the areas.” 

Alaska National Interest Lands Conservation Act of 1980 (ANILCA)

In 1990, the Tongass Timber Reform Act (TTRA) amended ANILCA and designated two new wilderness 

areas. Section 707 of ANILCA specifies that, “Except as otherwise expressly provided for in this Act, 

Wilderness designated by this Act shall be administered in accordance with applicable provisions of the 

Wilderness Act ...” 

Items expressly provided for in ANILCA wilderness that apply to this assessment include:

(1) Section 811 – Reasonable access for subsistence resource uses.

(2) Section 1110(a) – Special Access allowing for the use of airplanes, motorboats, and snowmachines

(during periods of adequate snow) within conservation system units as defined by Section 102 (4).

These rights may be subject to reasonable regulation to protect the natural and other values of the

conservation system units.

(3) Section of 1303(b)(1) – Allowance for the construction of new cabins and administrative cabins if

necessary for the administration of the area as wilderness.

(4) Section 1303(b)(2) – Allowance for the continuation of existing cabins.

(5) Section 1307(b) – Provides a preference for providing visitor services (except for fishing and

hunting) within conservation system units to Native Corporations and local residents.

- 21 - 
(6) Section 1315(c) – Allows for the permitting, maintenance, replacement, and continued use of

public use cabins.

(7) 1315(d) allows for the construction of new cabins if they are necessary for the protection of public

health and safety.

(8) Section 1316(a) – Allows for existing and future establishment of temporary structures necessary

for the taking of fish and game subject to reasonable regulation to insure compatibility, the

continuance of existing uses, and the future establishment, and use, of temporary campsites, tent

platforms, shelters, and other temporary facilities and equipment directly and necessarily related to

such activities.

(9) Section 1316(b) allows for the denial of the temporary facilities if the use of equipment or facilities

is determined to be detrimental to the wilderness character.

ANILCA exceptions may influence the character of some wildernesses more than others. During the 

evaluation of commercial recreation use for any one wilderness, an effort should be made to consider the 

long-term effects of accommodating increasing uses or proposals for new use. The economic benefits to a 

business are not a substantive basis of a decision to allow use presented in either the Wilderness Act or 

ANILCA.

Direction Provided by Regulation

Federal Regulations 36 CFR 293.2 – Objectives, states in part: “Except as otherwise provided in the 

regulations..., National Forest wilderness shall be so administered as to meet the public purposes of 

recreational, scenic, scientific, educational, conservation, and historical uses; and it shall also be 

administered for such other purposes for which it may have been established in such a manner as to 

preserve and protect its wilderness character...To that end:

(a) Natural ecological succession will be allowed to operate freely to the extent feasible.

(b) Wilderness will be made available for human use to the optimum extent consistent

with the maintenance of the primitive conditions.

(c) In resolving conflicts in resource use, wilderness values will be dominant to the extent not limited

by the Wilderness Act, subsequent establishing legislation, or the regulations in this part.”

Federal Regulations 36 CFR 293.8 - Permanent structures and commercial services, states in part that: 

“The Chief, Forest Service, may permit . . . commercial services within National Forest wilderness to the 

extent necessary for realizing the recreational or other wilderness purposes, which include, but are not 

limited to, the public services generally offered by packers, outfitters, and guides.” 

Forest Service Manual and Handbook Direction

Outfitters/guides must also meet agency objectives. These objectives are specifically outlined in the 

Forest Service Manuals (FSMs) and Forest Service Handbooks (FSHs).

FSM 2702 Special Uses Management states: 

The objectives of the Special Uses program are to:

- 22 - 
(1) 1Authorize and manage special uses of National Forest System lands in a manner which protects

natural resources and public health and safety, consistent with National Forest System Land and

Resource Management Plans;

(2) Administer special uses based on resource management objectives and sound business

management principles;

(3) Develop and maintain a well-trained workforce to properly manage and administer special uses;

and

(4) Facilitate the delivery of recreational opportunities on National Forest System lands for services

not provided by the Forest Service.

Forest Service Special Uses objectives specifically for outfitting and guiding, provided in FSH 2709.14, 

Chapter 50, Section 53.1b states:

(1) Provide for outfitting and guiding services that address concerns of public health and safety and

that foster successful small businesses consistent with the applicable land management plan.

(2) Facilitate greater participation in the outfitting and guiding program by organizations and

businesses that work with youth and educational groups.

(3) Encourage skilled and experienced individuals and entities to conduct outfitting and guiding

activities in a manner that protects environmental resources and ensures that national forest visitors

receive high-quality services.

Forest Service Special Uses policy for outfitting and guiding provided in FSH 2709.14, Chapter 50, 

Section 53.1c states: 

(1) Authorize only those outfitting and guiding activities that are consistent with the applicable land

management plan and that meet the screening criteria in 36 CFR 251.54(e) and FSH 2709.11,

chapter 10.

(2) Not authorize any development or permanent improvements in non-wilderness in the National

Forest System for outfitting and guiding services, except when there is a demonstrated public need

and the structures, improvements, or installations have negligible value and minimal impact on

national forest resources, as with hitching posts, corrals, tent frames, permitted access routes, and

shelters.

(3) Not authorize any development, improvements, or installations in wilderness areas for the purpose

of convenience to the holder or the holder’s clients; caches in wilderness areas; and permanent

structures, improvements, or installations in wilderness areas unless they are necessary to meet

minimum requirements for administration of the area for the purposes of the Wilderness Act (16

U.S.C. 1133c).

(4) Work with other Federal agencies, State and local authorities, outfitters and guides, outfitting and

guiding organizations, and other interested parties to ensure that outfitting and guiding activities are

consistent with applicable laws and regulations and to identify unauthorized outfitting and guiding

- 23 - 
activities. Follow procedures in FSM 5300 in investigating and preventing the occurrence of 

unauthorized outfitting and guiding activities.

Forest Service policy addressing outfitter and guide operations in wilderness found in FSM 2323.13g 

states that mangers should:

Address the need for and role of outfitters in the forest plan. The plan must address the type, number, and 

amount of recreation use that is to be allocated to outfitters. Ensure that outfitters provide their service to 

the public in a manner that is compatible with use by other wilderness visitors and that maintains the 

wilderness resource.

Objectives for wilderness management provided in FSM 2323.11 are to: 

(1) Provide, consistent with management of the area as wilderness, opportunities for public use,

enjoyment, and understanding of the wilderness, through experiences that depend upon a

wilderness setting.

(2) Provide outstanding opportunities for solitude or a primitive and unconfined type of recreation.

Forest Service policy addressing recreation management in wilderness in FSM 2323.12 states: 

(1) Maximize visitor freedom within the wilderness. Minimize direct controls and restrictions. Apply

controls only when they are essential for protection of the wilderness resources and after indirect

measures have failed.

(2) Use information, interpretation, and education as the primary tools for management of wilderness

visitors.

(3) Manage for recreation activities that are dependent on the wilderness environment so that a

minimum of adaptations within wilderness are necessary to accommodate recreation.

(4) Consistent with management as wilderness, permit outfitter/guide operations where they are

necessary to help segments of the public use and enjoy wilderness areas for recreational or other

wilderness purpose.

Tongass National Forest Land and Resource Management Plan Direction for 

Wilderness (pages 3-7 to 3-25)

Goals

To manage all designated wilderness to maintain an enduring wilderness resource while providing for 

public access and uses consistent with the Wilderness Act of 1964 and the Alaska National Interest Lands 

Conservation Act of 1980 (ANILCA). 

Protect and perpetuate natural biophysical and ecological conditions and processes. Ensure wilderness 

ecological systems are substantially free from the effects of modern civilization.

To provide a high degree of remoteness from the sights and sounds of humans, and opportunities for 

solitude and primitive recreation activities consistent with wilderness preservation.

Keep wilderness untrammeled and free from modern human control or manipulation, including actions 

taken to manage wilderness.

- 24 - 
Protect the undeveloped character of wilderness by following legislative guidelines regarding permanent 

improvements or modern human occupation, including mechanized transport and motorized equipment. 

Objectives

Apply a multi-disciplinary focus to wilderness management. The stewardship of the wilderness is 

considered in the annual program of work by all resources.

Manage recreation activities so the levels of social encounters, on-site developments, methods of access, 

and visitor impacts indicated for the Primitive Recreation Opportunity Class are emphasized. Areas 

managed as semi-primitive within a wilderness are an exception and are not encouraged. 

Provide for public use of the wilderness in accordance with ANILCA provisions for motorized and nonmotorized access and travel, including reasonable traditional subsistence use by rural residents.

Maintain trails and primitive facilities that are in harmony with the natural environment and that promote 

primitive recreation opportunities. Feature facilities designed primarily to provide resource protection and 

encourage smaller group size. Facilities tend to allow for challenge and risk instead convenience. 

Maintain the wilderness capacity to provide information on natural ecological processes

Preserve and perpetuate biodiversity 

Inventory, reduce, and when possible, eliminate non-native species in wilderness

Manage wilderness as a place where self-reliance and primitive skills are needed and can be honed.

Desired Condition

All designated wilderness on the Tongass National Forest is characterized by extensive, unmodified 

natural environments. Ecological processes and natural conditions are not measurably affected by past or 

current human uses or activities. Users have the opportunity to experience independence, closeness to 

nature, solitude and remoteness, and may pursue activities requiring self-reliance, challenge and risk. 

Motorized and mechanized use is limited to the minimum needed for the administration of the wilderness. 

Allow for access to state and private lands, subsistence uses, and for public access and other uses to the 

extent provided by ANILCA. If not specifically provided through an ANILCA exception, the resources 

within a designated wilderness shall be administered in accordance with the applicable provisions of the 

Wilderness Act.

The Forest Plan notes that; “Special Use Authorizations permitting individuals or organizations to provide 

visitor services in wilderness may be issued if there is a demonstrated need for the service(s) and they are 

deemed appropriate for the area proposed.”

- 25 - 
Determination of Need for Commercial Outfitter/Guide 

Services in the South Baranof Wilderness

Sitka Ranger District

- 1 - 
Table of Contents

Executive Summary ................................................................................................................ - 4 -

Determination of Need for Commercial Service Activities:................................................... - 4 -

Introduction ............................................................................................................................. - 4 -

South Baranof Wilderness ...................................................................................................... - 6 -

Area Description .............................................................................................................................. - 6 -

Access .............................................................................................................................................. - 8 -

Visitor Use ....................................................................................................................................... - 8 -

Subsistence Use ............................................................................................................................... - 8 -

Historic Use ..................................................................................................................................... - 9 -

Commercial Outfitter/Guide Use ..................................................................................................... - 9 -

Determination of Need for Commercial Services – .............................................................. - 11 -

Assumptions and Evaluation Criteria ................................................................................... - 11 -

Assumptions ................................................................................................................................... - 11 -

Evaluation Criteria ......................................................................................................................... - 11 -

Wilderness Dependence ................................................................................................................. - 11 -

Potential Impacts to Wilderness Character .................................................................................... - 12 -

Knowledge, Skills, and Equipment Required ................................................................................ - 14 -

Visitor Safety ................................................................................................................................. - 14 -

Outfitter and Guide Demand and Utilization ................................................................................. - 14 -

Public Purposes / Management Objectives .................................................................................... - 15 -

Determination of Need for Commercial Services by Activity .............................................. - 15 -

Activities Considered ............................................................................................................ - 15 -

Big Game Hunting – Brown Bear .................................................................................................. - 15 -

Big Game Hunting – Deer ............................................................................................................. - 16 -

Big Game Hunting – Mountain Goat ............................................................................................. - 18 -

Camping (including overnight use of public recreation cabins) .................................................... - 19 -

Floatplane Landing Tours .............................................................................................................. - 21 -

Freshwater Fishing ......................................................................................................................... - 22 -

- 2 - 
Remote Setting Nature Tours ......................................................................................................... - 24 -

Citations ................................................................................................................................ - 25 -

Appendix A. Management Direction .................................................................................... - 27 -

The Wilderness Act of 1964 .......................................................................................................... - 27 -

Alaska National Interest Lands Conservation Act of 1980 (ANILCA) ......................................... - 27 -

Direction Provided by Regulation .................................................................................................. - 28 -

Forest Service Manual and Handbook Direction ........................................................................... - 28 -

Tongass National Forest Land and Resource Management Plan Direction for Wilderness (pages 3-7 

to 3-25) ........................................................................................................................................... - 30 -

- 3 - 
Executive Summary

This document applies to the criteria of Section 4(d)6 of the Wilderness Act of 1964 (“Wilderness Act”) 

to determine which commercial recreation service activities may be necessary in the South Baranof 

Wilderness.

Commercial services may be performed within the wilderness areas designated by this Act to the extent 

necessary for activities which are proper for realizing the recreational or other wilderness purposes of the 

areas.

This assessment pertains solely to commercial recreation service activities. It does not consider other 

commercial or noncommercial uses. The need for commercial recreation service activities is determined 

by their ability to realize the recreational or other wilderness purposes of the Wilderness Act and their 

compatibility with preserving wilderness character.

This assessment concludes with a determination of need for seven commercial recreation service 

activities in the South Baranof Wilderness. Need was determined with a set of evaluation criteria that 

assessed the ability of activities to fulfill the purposes of the Wilderness Act and compatibility with 

preserving wilderness character. Market-generated demand for conducting outfitter and guide activities 

does not, by itself, constitute a need for commercial services. Identification of need also considers how an 

outfitter and guide operation can contribute to meeting the Tongass Land and Resource Management Plan 

(USDA Forest Service 2008b) management objectives. The following summarizes the findings. 

Determination of Need for Commercial Service Activities:

• Big Game Hunting for Brown Bear commercial service activities are necessary in the South

Baranof Wilderness

• Big Game Hunting for Deer commercial service activities are necessary in the South Baranof

Wilderness

• Big Game Hunting for Mountain Goat commercial service activities are necessary in the South

Baranof Wilderness

• Camping (including overnight use of public recreation cabins) commercial service activities are

necessary in the South Baranof Wilderness

• Floatplane Landing Tours commercial service activities are not necessary in the South Baranof

Wilderness

• Freshwater Fishing commercial service activities are necessary in the South Baranof Wilderness

• Remote Setting Nature Tours commercial service activities are necessary in the South Baranof

Wilderness

It is important to note that a determination of need does not imply that a commercial activity will 

be authorized for all locations in the South Baranof Wilderness. This document does not fully address 

the effects (e.g. social, physical) of existing and proposed commercial uses. Decisions regarding the 

appropriate types and levels of commercial use in particular locations will be accomplished in compliance 

with the National Environmental Policy Act. Guided activities will only be authorized to the extent 

consistent with the Wilderness Act’s direction to maintain wilderness character.

Introduction

The Forest Service has developed this needs assessment to determine the types of commercial 

outfitter/guide activities that could take place in the South Baranof Wilderness (SBW). A needs 

assessment is a methodology for determining if there is a ‘need’ for private enterprise to assist the agency 

in providing access, services and/or other assistance for the recreating public to enjoy National Forest 

- 4 - 
wilderness areas. This document is tiered to the Tongass Land and Resource Management Plan (“Forest 

Plan”; USDA Forest Service 2008b) and the Determination of Need and Extent of Commercial Uses 

within Wilderness Areas on the Tongass National Forest (USDA Forest Service 2007). Relevant 

management direction is provided in Appendix A. 

This needs assessment is part of a sequential process of evaluating commercial recreation use on National 

Forest System lands within wilderness. It only pertains to commercial recreation activities and not to 

other commercial or non-commercial uses. Other aspects of administering commercial recreation use 

outside the scope, but tiered to this assessment include: 

Visitor capacity is the amount of recreational use (both commercial and non-commercial) an area can 

accommodate given the desired natural conditions, visitor experiences, and management program. 

Visitor capacity is an administrative process to identify the reasonable amount of recreation 

opportunities that are consistent with management direction for an area. Once a capacity is 

determined it can be used as a tool to develop a proposed action for allocating commercial outfitter 

and guide use and environmental analysis.

Environmental analysis document per National Environmental Policy Act (NEPA) analyzes a 

proposed commercial outfitter and guide allocation of the overall recreation capacity and will 

establish mitigation measures that balance use with protection of the National Forest resource. These 

public planning processes inform decision makers of choices among alternative courses of action 

based upon resource capability and public input. 

A prospectus may be necessary to implement NEPA decisions when demand for commercially guided 

recreation opportunities exceeds the available capacity. A prospectus requires commercial operators 

to submit bid applications that meet specific criteria. The Authorized Officer allocates commercial 

use to businesses that best meet the criteria.

Special uses permits authorize individual outfitter and guides within the determined allocation and 

according to established mitigation measures.

The need for commercial services is determined by assessing the ability of activities to be compatible 

with the Wilderness Act of 1964 (“Wilderness Act”). A determination of need may be found where 

activities fulfill the purposes of the Wilderness Act and are compatible with preserving wilderness 

character. Market-generated demand for conducting outfitter and guide activities does not, by itself, 

constitute a need for commercial services. Identification of need also considers how an outfitter and guide 

operation can contribute to meeting Forest Plan management objectives. 

This needs assessment:

1. Determines the need for various activities of commercial outfitter and guide services

based on fulfilling the purposes of the Wilderness Act and compatibility with preserving

wilderness character within the SBW.

2. Is an internal analysis.

3. Does not analyze or mitigate potential environmental impacts from commercial outfitting

and guiding activities.

4. Does not determine, establish, allocate or authorize commercial outfitter and guide

services.

Outfitter/guides can serve as important partners for the Forest Service. In particular, they can provide 

wilderness awareness and Leave No Trace education for visitors that may not be reached by other 

educational efforts. Outfitter/guides can also assist with monitoring activities, such as reporting invasive 

plants and illegal activities; these activities help the Forest Service achieve a higher level of wilderness 

stewardship. 

- 5 - 
Existing outfitter/ guide activities occurring in SBW are authorized under the Shoreline Outfitter/Guide 

Record of Decision and Final Environmental Impact Statement (USDA Forest Service 2004). This 

decision is currently under review. 

South Baranof Wilderness

Area Description

The South Baranof Wilderness (SBW; Figure 1) includes 319,568 acres of coastal temperate rainforest. 

Numerous bays along the area’s rugged shoreline cut deep into the mountainous interior of Baranof 

Island, providing safe anchorage for boats in an otherwise exposed ocean environment. The community of 

Sitka lies approximately 19 miles to the north of the SBW and Port Alexander is approximately 20 miles 

to the south. 

At 4,528 feet, Mount Ada is the highest peak in the SBW. On the eastern side of Baranof Island, Mount 

Ada’s peak lies less than three miles from saltwater. Permanent snowfields and active glaciers blanket the 

higher elevations and several high-elevation lakes offer outstanding recreation opportunities. The SBW is 

part of the temperate rainforest that extends along the Pacific coastline from northern California to Cook 

Inlet, Alaska. Most of the area's lower-elevations offer old-growth western hemlock and Sitka spruce, 

with a scattering of yellow cedar and mountain hemlock. 

SBW receives an average of 200 inches of precipitation per year with temperatures ranging from mid-20s 

to high 60s. Wildlife includes brown bears, Sitka black-tail deer, mountain goat, mink, marten, and river 

otters; trout and salmon (seasonally); as wells as eagles and shorebirds. Seals, sea lions, whales, and a 

large population of sea otters are often seen offshore, and crab, shrimp, herring, salmon and halibut are 

harvested from the ocean.

The area supports a full range of life zones, from the marine to the alpine. It is this combination of rugged 

mountains, glaciers, dense rainforest, and the sea that gives the SBW its variety and high value as 

"wilderness." 

- 6 - 
Figure F5-1. South Baranof Wilderness vicinity map. 

- 7 - 
Access

Weather, marine conditions, and terrain make this remote area difficult to access. Much of the high 

mountains are permanently snow covered and the scenery is dramatic. Access to high-elevations lakes is 

difficult due to the steep terrain, particularly in the northern portion of the wilderness. Motorized boat, 

floatplane and kayak are the methods of access primarily used to visit the SBW. Most of the upland use in 

SBW is accessed by floatplane. Visitors can hire air taxi operators to provide transport services to lakes 

without a Forest Service special use permit. Upland areas are used for hunting, fishing, overnight use of 

public recreation cabins, and hiking. It is possible, though difficult, to access some of the lakes by foot 

from saltwater. There is also increasing interest in cross-island hiking trips and pack-rafting some of the 

interior lakes. 

The long and narrow steep-sided bays on the west side provide a limited number of protected anchorages, 

resulting in a concentration of use at certain locations. The northwestern portion of the wilderness is 

comprised of large and small islands offering more protected passages for boaters, providing relatively 

easy access for the skilled skiff operator or kayaker due to proximity to Sitka. The east side provides 

several protected bays for taking a break from the open waters of Chatham Strait, and Red Bluff Bay is a 

common stopping point for those traveling inside waters around Admiralty Island. 

There are concerns about the impacts of motorized transport, particularly floatplanes and motorized boats, 

in some areas of the SBW. The Alaska National Interest Lands Conservation Act of 1980 (ANILCA) 

allows for the use of motorized boats and planes to access SBW, but does not discuss their use for 

commercial outfitting and guiding purposes. Ultimately, the Forest Service must ensure that the area is 

administered for the use and enjoyment of the American people leaving it unimpaired for future use and 

enjoyment as wilderness while protecting the area and preserving its wilderness character (Wilderness 

Act, Section 2(a)). 

Visitor Use

South Baranof Wilderness provides a diversity of recreation, subsistence, commercial and personal use 

opportunities. Most activities take place in, and depend on, settings that are primarily undeveloped. The 

entire area is wild and remote, with no road access available. Recreation facilities are limited, consisting 

of three public recreation cabins and one short system trail between Plotnikof Lake Cabin and the south 

end of Davidof Lake. Plotnikof Lake Cabin receives the most use of the three with an average of 15 

nights annually (2009-2013). Avoss Lake Cabin receives 13 nights of use on average (2009-2013) 

followed by Davidof Lake Cabin with 6 nights (2009-2013). 

Recreation activities cover a broad spectrum of uses, including sightseeing, wildlife viewing, fishing, 

hunting, kayaking, camping, and hiking. Some of the lakes support a good trout sport fishery and most 

streams and inlets support good salmon sport fishing. Port Banks, in particular, is known for a spring 

steelhead run, early summer coho run, and a fall run of coho making this a popular location throughout 

the fishing season. Politofski Lake Creek and Sandy Bay also support popular steelhead fisheries in the 

spring. However, most fishing in the area is commercial and occurs in the saltwater adjacent to the 

wilderness. Marine passages and bays are used for boating, crabbing, shrimping, and personal and 

commercial fishing. 

Subsistence Use

On the eastern side of Baranof Island, the people of Kake and Angoon have traditional ties to this area 

and continue to depend on resources within the wilderness for a part of their livelihood. Sockeye salmon 

are harvested for subsistence purposes from Gut Bay and the Falls Lake system. The west side of the 

- 8 - 
wilderness is used by residents of Sitka and Port Alexander for sockeye salmon from the Benzeman Lake 

and Politofski Lake streams. Table 1 shows the subsistence fishing seasons for these areas:

Table F5-1. Subsistence Fishing Seasons.

Stream Subsistence Fishing Season

Falls Lake June 1 – August 15

Gut Bay June 1 – July 20

Necker Bay June 1 – August 31

Politofski June 1 – July 31

Subsistence hunting and trapping occurs seasonally by the above mentioned communities. These 

activities are not intensive on the east side because of game animals and furbearers that are much closer to 

Kake and Port Alexander. 

Historic Use 

Unlike other parts of the Tongass National Forest, the area contained within the SBW boundary does not 

have an active mining history. There have been uses related to the early commercial fishing industry in 

the area. These include a cannery and herring reduction plant in Red Bluff Bay operating through the 

1930’s. Remains of this activity can be seen on the ground and draw some visitation to the site. Whale 

Bay area saw heavy commercial fishing use starting in the 1920s and a store was established during that 

timeframe in Port Banks. The old structure is still visible. In addition, historic cabin structures have been 

found in the Yamani Islets and on Lodge Island. The sites that still have evidence of past use have the 

potential to draw visitors interested in exploring historic ruins. 

Commercial Outfitter/Guide Use

Thirty-five outfitter/guides were permitted and providing visitor services in SBW between 2008 and 

2012; their activities provide services for forest visitors that are unfamiliar with southeast Alaska’s 

wilderness. Authorized outfitted and guided activities include big game hunting for brown bear, mountain 

goat, and deer; remote setting nature tours (including hiking, beach use, and wildlife viewing), camping, 

and freshwater fishing. There was also a small amount of waterfowl and small game hunting that occurred 

in association with brown bear hunts. 

Outfitter/guides are required to submit use reports annually that identify the use location, type of use, 

number of clients, number of groups, and length of stay at each location. From this information, the 

number of service days used at each location is calculated. A service day is defined as a day, or any part 

of a day, on National Forest System lands for which an outfitter/guide provides goods or services, 

including transportation, to a client. Actual use reports provide an effective mechanism to track and 

monitor outfitter and guide use in wilderness. Table 2 shows the type and amount of outfitter/guide use 

that occurred on SBW between 2008 and 2012. 

Table F5-2. Outfitter and guide activities occurring in SBW, 2008-2012. 

Activity 2008 2009 2010 2011 2012 Average Annual 

Use 

2008-2012

Big Game Hunting –

Brown Bear 

53 88 105 107 46 80

Big Game Hunting –

Deer

0 0 1 0 2 1

Big Game Hunting –

Mountain Goat

59 17 46 0 4 25

Camping 35 84 44 132 54 70

- 9 - 
Freshwater Fishing 251 293 244 206 225 244

Remote Setting 

Nature Tours 

(including hiking, 

wildlife viewing, 

photography, and 

beach use)

267 115 111 297 212 200

1 A service day is defined as a day, or any part of a day, on National Forest System lands 

for which an outfitter or guide provides goods or services, including transportation, to a 

client.

Freshwater fishing and remote setting nature tours (including hiking, wildlife viewing, photography, and 

beach use) are the most popular guided activities occurring in the SBW. Brown bear hunting, camping, 

and mountain goat hunting are also popular guided activities. The Forest Service has also received 

proposals for guided use at low-use public recreation cabins in SBW, but this use has not been authorized. 

Nineteen guides provided freshwater fishing trips in the SBW between 2008 and 2012. Most freshwater 

fishing is accessed by motorized boat and occurs within a 1⁄2-mile distance of the shoreline, in the creeks 

and bays supporting anadromous fish populations. Gut Bay Creek, Politofski Lake Creek, Port Banks, 

Red Bluff Bay Creek, and Sandy Bay are the most popular guided fishing locations. Port Banks and 

Politofski Lake Creek support a steelhead run during April and May, which draws catch-and-release fly 

fishing operators. A small amount of fishing also occurs on Brentwood, Pass, Plotnikof, Politofski, 

Rezanof, and Upper Brentwood Lakes. One operator has been authorized to provide fly-in fishing trips in 

SBW. There have been several requests from guides for fly-in access for fishing and remote setting nature 

tours at lakes in the SBW, particularly lakes supporting steelhead populations. 

Twenty-three guides provided guided remote setting nature tours (includes hiking, wildlife viewing, 

photography, and beach use) in SBW between 2008 and 2012. The most popular remote setting nature 

tour activity in SBW is hiking at Red Bluff Bay. Guides have reported using approximately 96 service 

days per year at Red Bluff Bay for remote setting nature tours activities. Other locations of interest 

include Gut and Patterson Bays. 

Guided brown bear hunters typically access the SBW via motorized boat and camp onboard the boat 

during their hunt. In spring, they scan the shoreline beaches from their vessel before beginning their stalk. 

More use occurs in the uplands during the fall season when hunters often travel by foot along streams. 

Floatplane access for brown bear hunting at lakes in SBW has been authorized in the past, but all reported 

use (2008-2012) has occurred in coastal inlets and bays accessed from saltwater. 

Guided mountain goat hunts also occur in SBW; popular locations include Crawfish, Hoggatt, and Red 

Bluff Bays. A small amount of guided mountain goat hunting has been reported in the uplands of 

Politofski Lake. The majority of goat hunts are boat-based, with occasional use of spike camps in the 

uplands. Floatplane access for guided mountain goat hunting at inland lakes has been authorized and 

reported in the past. Most hunts last approximately seven days and hunters may hike to the alpine once or 

twice during a hunt. Camps are typically occupied for a few nights each season. Non-guided hunters 

typically access high lakes in SBW for goat hunting in the early fall before guides begin conducting 

hunts, but there is some overlap in November. Access to herds is difficult and use tends to be 

concentrated at a few areas. 

A small amount of guided deer hunting occurs in association with guided brown bear and mountain goat 

hunts; clients are given the option of including a deer hunt as part of a package, with the target species 

still being brown bear or mountain goat. In recent years, however, there has been an increased interest in 

guided deer-only hunting in SBW, with two guides currently authorized in SBW for deer-only hunts. 

- 10 - 
Three outfitter/guide companies have offered guided camping tours in SBW (2008-2012). Camping is 

usually offered as part of a multi-day, kayak- or motorized boat-based excursion and occurs along the 

shoreline of Baranof Island and the smaller, surrounding islands. Actual use locations include Patterson 

Bay, Rakof Islands, Lodge Island, Cedar Pass, West Crawfish Inlet, and Beauchamp Island. There have 

also been requests to utilize the existing public-use cabins for fly-in camping excursions at the lakes 

within SBW. 

Determination of Need for Commercial Services - Assumptions and 

Evaluation Criteria

Assumptions

The following are assumptions made to aid in the assessment of the need for outfitter/guide operations: 

• Some people would not visit the SBW without an outfitter or guide because they lack the skills,

knowledge, equipment, or ability to do so on their own, or they have safety concerns.

• There will be a continued demand for special use permits to conduct outfitter and guide

operations in the SBW. Access points and use locations are generally limited to safe harbors and

accessible beaches. Increased demand and use levels at popular locations are issues to consider.

• Overall visitor use is expected to remain at current levels or continue to increase (Forest Plan).

There may also be shifts in use patterns (timing and location) and user types (hikers, backpackers,

campers, day users, etc.).

• Visitor conflicts have the potential to increase if overall use increases. Conflicts are already

occurring in some areas on the district, particularly between guided bear hunters and visitors

participating in other types of activities (e.g. freshwater fishing, remote setting nature tours).

Guided and unguided groups tend to participate in similar activities at similar locations.

Evaluation Criteria

The following criteria were used to determine the public need for commercial outfitter and guide services 

in SBW:

• Wilderness Dependence

• Potential Impacts to Wilderness Character

• Knowledge, Skills, and Equipment Needed

• Visitor Safety

• Outfitter and Guide Demand and Utilization

• Public Purpose & Management Objectives

Wilderness Dependence

The Forest Plan directs managers to “Avoid authorizing uses that are not dependent upon Wilderness 

resources or uses for which reasonable alternative locations exist outside of Wilderness” (USDA Forest 

Service 2008b, p.3-12). Determination of need is based on the extent to which the proposed service can or 

cannot be offered on non-wilderness National Forest System (NFS) lands or non-NFS lands, including 

private or other public lands. Wilderness dependence may also be considered for 1) trips in which solitude 

or primitive and unconfined recreation are the central components of the experience; and 2) visits to 

ecosystems, geological features, or physical resources found predominantly in wilderness for recreational, 

scientific, or educational purposes.

- 11 - 
This needs assessment is one part of a sequential process of administering commercial recreation use on 

NFS lands within wilderness. Applications for outfitter and guide use in SBW must include adequate 

justification for why the proposed activity requires the use of wilderness. 

Potential Impacts to Wilderness Character 

Determination of need is based on the extent to which outfitter and guide activities have the potential to 

degrade or improve wilderness character. The Wilderness Act specifies that “each agency administering 

any area designated as wilderness shall be responsible for preserving the wilderness character of the area” 

(Section 4(b)). The wilderness character of SBW is largely intact due to the area’s remoteness, 

challenging terrain, and limited means of access. There are, however, some areas where wilderness 

character is affected by recreational use. Section 2(c) of the Wilderness Act defined four qualities of 

wilderness character that managers shall try to preserve, including the following: 

• Untrammeled – The wilderness is essentially unhindered and free from modern human control

or manipulation. This quality describes the degree to which management actions “hinder” or

“control” the land and natural processes. For example, the wilderness area has remained free of

management activities that have altered natural systems, such as dams or regulations that govern

visitor activities. Outfitter and guide activities generally do not affect the untrammeled quality of

wilderness character.

• Natural - Wilderness ecological and evolutionary systems are substantially free from the effects

of modern civilization. This quality describes the ecological effects of human activities on

vegetation, soils, air quality, or other physical and biological components of wilderness. Outfitter

and guide activities have the potential to impact the natural qualities of wilderness character.

• The natural quality of wilderness character in SBW is largely unaffected by past and present

human activity; however there are some noted instances of effect:

• Three non-native plant species, covering less than 0.1 acres, have been documented.

• Red squirrels, marten, beaver, and mountain goat have been introduced. Coho salmon

were stocked in Banner and Blanchard Lakes in the 1980s.

• In 1982, a permit was issued to the Tlingit and Haida Fisheries Development

Corporation for the construction of a fish hatchery in Sandy Bay at the outlet of the

Maksoutof River. The hatchery was constructed in 1982. Due to various problems which

occurred during the hatchery's operation, the facility closed in 1985. In 1993, most of the

remains of the hatchery were removed and the ground was recontoured to eliminate the

man-made berms and rectangular race-way holes. Some materials still remain on site.

• Forest Service employees have documented vegetation impacts (primarily tree cutting) at

Port Banks and Sandy Bay.

• Undeveloped - Wilderness retains its primeval character and influence and has minimal

evidence of modern human occupation or modification. This quality describes the effects of

structures, habitations, or other evidence of human presence or occupation.

• The past and current presence of humans is evident in some parts of SBW. Existing developments

include the Falls Lake fish weir and Patterson Bay net pen shoreties. The remains of past

developments include the Sandy Bay hatchery as well as a cannery and herring reduction plant in

Red Bluff Bay operating through the 1930’s. Whale Bay area saw heavy commercial fishing use

starting in the 1920s and a store was established during that timeframe in Port Banks. The old

structure is still visible. In addition, historic cabin structures have been found in the Yamani Islets

and on Lodge Island.

• The Forest Service maintains three public recreation cabins in SBW, including the Avoss Lake,

Davidof Lake, and Plotnikof Lake Cabins. Two additional cabins at Rezanof and Maksoutof

Lakes exist, but are identified for decommission and removal. Impacts at cabins and dispersed

- 12 - 
campsites include tree damage, litter, fire ring construction, and social trails. Outfitters and guides 

are required to practice Leave No Trace to minimize these impacts. 

• In general, there is less evidence of human occupation or modification as one travels inland from

the shoreline zone. Outfitter and guide activities that require the use of temporary or permanent

structures, or create noticeable impacts on the ground, have the potential to further impact the

undeveloped quality of wilderness character in SBW.

• Outstanding opportunities for solitude or a primitive and unconfined type of recreation.

Wilderness provides outstanding opportunities for people to experience natural sights and

sounds, solitude, freedom, risk, and the physical and emotional challenges of self-discovery and

self-reliance.

• Noise associated with motorized transport (e.g. motorized boats and float planes) has the potential

to diminish wilderness character by reducing opportunities for solitude. Some parts of the

wilderness lie on the path of weekly flights heading south from the community of Sitka as well as

daily jet flights in the region, which affect noise levels in the southern portion of SBW,

particularly during the summer months. While some motorized activities occur in the air and on

the marine waters adjacent to SBW and are outside of Forest Service jurisdiction, other activities

(e.g. floatplane landings on lakes and shoreline excursions associated with motorized transport)

are within Forest Service jurisdiction and require a special use authorization.

• Red Bluff Bay is a popular location; social encounter monitoring during late June (2012 - 2013)

and late July (2011-2013) indicates visitors can expect to encounter on average eight or more

groups per day in the bay. The majority of this use is occurring on the adjacent saltwater. Land

access that occurs is typically via motorized boat, with some access via kayak off nearby mother

ships.

• Competition for use at lakes and streams occasionally occurs, particularly during the overlapping

brown bear hunting season (April – May) and steelhead fishing seasons (April - June) at Port

Banks, Politofski Lake Creek, and Sandy Bay, coho season (June – July and September-October)

at Port Banks, sockeye season (June – August) at Gut Bay, Necker Bay, and Politofski Lake

Creek, and early in the mountain goat hunting season (August-October).

• Opportunities for solitude are greater in the interior and northern portions of the SBW; upland

areas receive fewer visitors due to the lack of facilities and difficult lake landings. The terrain is

mountainous and generally without facilities or trails.

• Other Features of Value. This quality pertains to distinct features fundamental to the wilderness

character that are not contained within the other qualities. This aspect is based on the last clause

of Section 2(c) in the Wilderness Act, that a wilderness “may also contain ecological, geological,

or other features of scientific, educational, scenic, or historical value.” This fifth quality is unique

to an individual wilderness based on the features that are inside that wilderness. These features

typically occur only in specific locations within a wilderness and include cultural resources,

historical sites, paleontological sites, or any feature not in one of the other four qualities that has

scientific, educational, scenic, or historical value. The following unique qualities are associated

with SBW:

• Red Bluffs – Red Bluff Bay is one of the primary attractions in SBW due to the scenic

mountain landscape surrounding the bay, waterfalls, brown bear viewing in the estuary, and

the “red bluffs” rising above the entrance to the bay. The bluffs are a unique geologic

feature of the area composed of serpentinites and serpentinized periodotites.

• Glacial Features - Unique to Baranof Island, among the hundreds of islands which make

up the southeast Alaska panhandle, are it's active glaciers. Associated with these glaciers

are narrow, sharp ridges between U-shaped glacial valleys and scenic fiords. Numerous

rocky crests, sharp ridges, horns, aretes and cirques are found at higher elevations. Snow

can be seen year round on higher summits with cirque glaciers and small permanent

icefields, especially in the north half of the area.

- 13 - 
• Brown Bear - Admiralty, Baranof, and Chichagof Islands together are considered unique

due to the singular large predator (brown bear) dominating these landscapes.

• Historic and Pre-Historic Values - Since pre-historic times the lands within the SBW

have supported a broad range of human use, development and occupancy. Thousands of

years ago South Baranof became an area of seasonal habitation by local native peoples.

Little is known about the prehistoric use of the present-day wilderness. There are a few

documented prehistoric sites, but surveys have been very limited. Later, Russians and

Americans arrived. Despite the continual presence by humans, the wilderness character of

the area remained virtually uncompromised until the early 1900s when commercial fishing

and whaling operations occurred and facilities in support of these activites were established

(e.g., cannery, herring reduction plant). Since 1950, the facilities have been discontinued

and many of the sites are being reclaimed by nature.

• Subsistence Use - Gathering wild food and other items has been an integral part of the

way of life in southeast Alaska for thousands of years. The people of Kake and Angoon

have traditional ties to this area and continue to depend on resources within the wilderness

for a part of their livelihood. Sockeye Salmon are harvested for subsistence purposes from

Gut Bay and the Falls Lake system. The west side of the wilderness is used by residents of

Sitka and Port Alexander for taking sockeye salmon from the Benzeman Lake and

Politofski Lake streams. Subsistence hunting and trapping occurs seasonally by the above

mentioned communities. These activities are not intensive on the east side because of game

animals and furbearers that are much closer to Kake and Port Alexander.

Knowledge, Skills, and Equipment Required 

Determination of need is based on the degree to which outfitter and guide services are needed by the 

public because 1) the specific skills required for activities appropriate to the area require substantial time 

and/or talent to learn; 2) participating in the activity requires acquisition and use of expensive, specialized 

equipment for which the public could not, or ordinarily would not, expend the time and money; and 3) the 

skills, knowledge, and equipment required are so unique that the use of an outfitter or guide is almost a 

prerequisite if area visitors are to have the opportunity to participate safely, while still achieving a level of 

self-reliance and challenge in the activity. Outfitters and guides possess knowledge about the local area 

and wilderness resource that may be required to safely access the area and minimize resource damage and 

visitor conflicts. This knowledge may include knowing where, and by what method, to best access and 

travel through an area.

Visitor Safety

Determination of need is based on the degree to which outfitter and guide services are needed by the 

public because of the special skills, knowledge, and equipment needed for a reasonable level of visitor 

safety. Without guide assistance, members of the public and visitors to the area may seriously endanger 

their health or lives, or would not visit the wilderness area due to safety concerns. Outfitter and guide 

services should not diminish other wilderness visitors’ opportunities to experience a degree of challenge 

and risk, and/or sense of self-reliance. 

Outfitter and Guide Demand and Utilization

Determination of need is based on the amount of demand that exists for an outfitter and guide activity and 

the extent to which the activity is already authorized, and the amount of use currently occurring. Marketgenerated demand for conducting outfitter and guide activities does not, by itself, constitute a need for 

commercial services. However, the determination of public need for a service is informed by examining 

current and past use trends. 

- 14 - 
Public Purposes / Management Objectives

The Wilderness Act specifies that “wilderness areas shall be devoted to the public purposes of 

recreational, scenic, scientific, educational, conservation, and historical use” (Section 4(b)). 

Determination of need is based on the extent to which guide services help fulfill these public purposes of 

wilderness. Determination of need is also based on the degree to which outfitters and guides help the 

Forest Service meet management objectives to 1) provide opportunities for public use, enjoyment, and 

understanding of the wilderness through experiences that depend upon a wilderness setting and are 

consistent with management of the area as wilderness, and 2) provide opportunities for special 

populations, including persons with disabilities and the elderly, to access certain areas and participate in 

recreational and educational activities. Guides can serve as important partners for the Forest Service by 

providing wilderness awareness education and training in outdoor skills and ethics. Consideration will 

also be given to the compatibility of commercial use with use by the general public. 

Determination of Need for Commercial Services by Activity

Activities Considered

A review of past and current outfitter and guide use in the SBW provided a starting point for this needs 

assessment. Based on past proposals and actual use, the following commercial outfitter and guide 

activities were considered:

• Big Game Hunting for Brown Bear

• Big Game Hunting for Deer

• Big Game Hunting for Mountain Goat

• Camping (including overnight use of public recreation cabins)

• Floatplane Landing Tours

• Freshwater Fishing

• Remote Setting Nature Tours

This assessment may be revised in the future as recreation use patterns change and demands for new 

outfitter/guide services are identified. 

Big Game Hunting – Brown Bear 

Brown bear hunting includes day use and overnight activities in the wilderness. Activities incidental to 

the primary brown bear hunt may involve camping, remote setting nature tour activities, freshwater 

fishing, or hunting for lower value game and waterfowl species. 

Table F5-3. Brown Bear Hunting needs.

Evaluation Criteria Evaluation of Need

Wilderness 

Dependence

Guide Use Areas (GUAs) 04-01 and 04-02 encompass the SBW. Both GUAs have 

large tracts of non-wilderness National Forest System (NFS) lands with suitable 

bear habitat. There is also some municipal land at Green Lake, and along the Green 

Lake Road, however these areas are characterized by a more urban setting. City 

land may also be available at Goddard Hot Springs, but this area receives a large 

amount of visitation and may not provide the visitor experience sought by guided 

bear hunters. 

Wilderness Character Natural Quality: The majority of guided hunting in SBW and surrounding areas on the 

Tongass National Forest is boat-based and results in minimal impacts to vegetation, soil, 

and water resources. Guided groups typically stay aboard a boat and hike up streams 

and very little use occurs in the uplands. ADF&G provides recommendations, population 

estimates, and historical harvest data to help the Forest Service determine the number 

of guided hunts an area can sustain. 

- 15 - 
Undeveloped Quality: Guided hunting groups have the potential to impact the 

undeveloped quality of wilderness if tent platforms are constructed or remain in place 

when not in use.

Outstanding Opportunities for Solitude or Primitive & Unconfined Recreation Quality: 

Guided groups also have the potential to impact opportunities for solitude, particularly 

if access is by motorized boat or floatplane, and use occurs in popular areas. Conflicts 

have been reported between guided bear hunting groups and other permitted users, 

such as freshwater fishing and remote setting nature tour groups. Conflicts with 

unguided visitors are less common as brown bear hunting is not a popular unguided 

activity. 

Other Features of Value

Brown Bear – ADF&G manages the brown bear population to ensure long-term 

sustainability of the resource.

Skills, Equipment, and 

Knowledge Required 

Visitors primarily access the SBW using motorized boats or float planes. Outfitters 

and guides can provide the skills, equipment, and knowledge required to safely 

access and enjoy the wilderness. The Alaska Department of Fish and Game 

(ADF&G) requires non-resident brown bear hunters to be accompanied by a 

registered guide or a relative within the second degree of kin. The knowledge and 

skills required to identify male bears and properly care for the animal carcass in 

accordance with State law are beyond the average person’s abilities. 

Visitor Safety Southeast Alaska’s weather conditions and tidal fluctuations can be extreme 

throughout the year. Exposure to wind and cold weather poses a threat to visitor 

safety. Wildlife encounters, particularly with brown bear, also pose a risk to safety. 

Guides know how to track and retrieve animals, carry radios and/or satellite 

phones for communication, and carry back-up rifles in case of emergency.

Outfitter and Guide 

Demand and Utilization

There is consistently high demand for guided brown bear services in SBW. An 

average of 80 service days was reported annually for this activity (2008-2012). 

Most authorizations are being fully utilized by existing guides. There are also 

several prospective applicants should more guided brown bear hunts become 

available. Most guides are booked years in advance for these hunts. 

Public Purposes & 

Special Management 

Objectives

Guided brown bear hunting contribute to the recreational purpose of wilderness. 

Guides can also help the ADF&G male to female harvest ratio objectives and ensure 

that hunters care for and process carcasses in accordance with State law. Guide 

hunt records also help track harvest locations and success rates, contributing to 

better management of bear populations. Guides can also teach clients about lowimpact skills. 

Outfitter/guides provide access to brown bear hunting opportunities in SBW that would otherwise be 

unavailable to many members of the general public because of the high level of knowledge, skills, and 

equipment needed to safely conduct a remote hunt. Outfitters and guides also help the Forest Service meet 

special management objectives for dispersing impacts related to nonresident harvest. This activity 

contributes to the recreational purpose of wilderness and has little resource concerns. These factors, along 

with the State of Alaska’s requirement for non-resident hunters to be accompanied by a licensed guide, 

indicate there is a need for outfitter/guide brown bear hunting services in SBW. Guides can educate 

clients about low-impact skills to minimize impacts to the natural and undeveloped qualities of wilderness 

character.

Big Game Hunting – Deer 

Deer hunting includes day use and overnight activities in the wilderness. Activities incidental to the 

primary deer hunt may involve camping, remote setting nature tour activities, freshwater fishing, or 

hunting for lower value game and waterfowl species. 

Table F5-4. Deer Hunting needs.

Evaluation Evaluation of Need

- 16 - 
Criteria

Wilderness Dependence Guide Use Areas (GUAs) 04-01 and 04-02 encompass the SBW. Both GUAs have 

large tracts of non-wilderness National Forest System (NFS) lands with suitable deer 

habitat. A limited amount of private land (Shee Atika Incorporated) could be available 

in Katlian Bay. Permission would need to be secured. There is also some municipal land 

at Green Lake, and along the Green Lake Road, however these areas are characterized 

by a more urban setting. City land may also be available at Goddard Hot Springs, but 

this area receives a large amount of visitation and may not provide the visitor 

experience sought by guided deer hunters.

Wilderness Character • Natural Quality: The majority of guided hunting in SBW and surrounding areas on 

the Tongass National Forest is boat-based and results in minimal impacts to 

vegetation, soil, and water resources. The majority of deer hunts are boat-based, with 

occasional use of spike camps in the uplands. Camps are typically occupied for a few 

nights each season, but because they are located in alpine areas, impacts could 

become noticeable with a small amount of use. ADF&G provides recommendations, 

population estimates, and historical harvest data to help the Forest Service 

determine the number of guided hunts an area can sustain. 

• Undeveloped Quality: Guided hunting groups have the potential to impact the 

undeveloped quality of wilderness if tent platforms are constructed or remain in 

place when not in use. 

• Outstanding Opportunities for Solitude or Primitive & Unconfined Recreation 

Quality: Guided groups have the potential to impact opportunities for solitude, 

particularly if access is by motorized boat or floatplane, and use occurs in popular 

areas. Guided hunting groups typically consist of 2-4 hunters plus guides. 

Occasionally two groups will camp together and hunt different areas. Due to the 

nomadic approach taken for deer hunting, and the small size of groups involved, the 

potential for visitor conflicts is minimal. Currently, conflicts are uncommon with 

guided deer hunters and non-guided or subsistence hunters due to the limited 

amount of guided use that has occurred. 

• Other Features of Value: 

o Subsistence use has historically occurred in this wilderness area. If demand 

for guided deer hunting increases, consideration will need to be made for 

subsistence users. 

Skills, Equipment, and 

Knowledge Required 

Visitors primarily access the SBW using motorized boats or float planes. Outfitters and 

guides can provide the skills, equipment, and knowledge required to safely access and 

enjoy the wilderness. A guide can ensure that State regulations and ethical hunting 

procedures are followed. Guides are also knowledgeable about deer behavior and where 

conflicts with unguided visitors may occur. There is no State requirement for a 

registered guide for deer hunting.

Visitor Safety Southeast Alaska’s weather conditions and tidal fluctuations can be extreme throughout 

the year. Exposure to wind and cold weather poses a threat to visitor safety. Wildlife 

encounters, particularly with brown bear, also pose a risk to safety. There have been 

documented incidents of deer hunters being attacked by brown bear. Guides carry radios 

and/or satellite phones for communication and back-up rifles in case of emergency. 

Outfitter and Guide 

Demand and Utilization

Between 2008 and 2012, there was a low level of demand for guided deer hunting. Most 

guided deer hunting occurs as incidental take to a bear or goat hunt, or as part of 

combination hunt for bear and deer. Five permits have been issued authorizing 38 deer 

hunts; only two of these were exclusively for deer hunting. None of these permits has 

been fully utilized. Recently, there has been an increased demand for adding deer hunts 

to existing big game hunting permits. 

- 17 - 
Public Purposes & 

Special Management 

Objectives

Guided deer hunting contributes to the recreational purpose of wilderness. Guide hunt 

records help track harvest locations and success rates, contributing to better 

management of deer populations. Guides can also teach clients about low-impact 

camping and hiking skills.

Outfitter/guides provide access to deer hunting opportunities in SBW that would otherwise be unavailable 

to many members of the general public because of the high level of knowledge, skills, and equipment 

needed to safely conduct a remote hunt. Outfitters and guides also help the Forest Service meet special 

management objectives for dispersing impacts related to nonresident harvest. This activity contributes to 

the recreational purpose of wilderness and results in limited impacts to Forest resources, including 

wilderness character. These factors indicate there is a need for outfitter/guide deer hunting services in 

SBW. Guides can educate clients about low-impact camping and hiking skills to minimize impacts to the 

natural and undeveloped qualities of wilderness character.

Big Game Hunting – Mountain Goat 

Mountain goat hunting includes day use and overnight activities in the wilderness. Activities incidental to 

the primary goat hunt may involve camping, remote setting nature tour activities, freshwater fishing, or 

hunting for lower value game and waterfowl species. 

Table F5-5. Mountain Goat Hunting needs. 

Evaluation 

Criteria

Evaluation of Need

Wilderness Dependence The majority of accessible goat herds on National Forest System (NFS) lands within the 

Sitka Ranger District occur outside of wilderness, particularly in the area north of Sitka. 

These non-wilderness NFS lands are also more heavily used by local residents. With the 

exception of Katlian Valley and Medvejie, there are no private lands in the vicinity of 

SBW where goats occur during the hunting season. 

Wilderness Character • Natural Quality: ADF&G provides recommendations, population estimates, and 

historical harvest data to help the Forest Service determine the number of guided 

hunts an area can sustain. The majority of goat hunts are boat-based, with occasional 

use of spike camps in the uplands. Hunts generally last approximately seven days 

and hunters may hike to the alpine once or twice during a hunt. Camps are typically 

occupied for a few nights each season, but because they are located in alpine areas, 

impacts could become noticeable with a small amount of use. 

• Undeveloped Quality: Guided hunting groups have the potential to impact the 

undeveloped quality of wilderness if tent platforms are constructed or remain in 

place when not in use. 

• Outstanding Opportunities for Solitude or Primitive & Unconfined Recreation 

Quality: Guided groups have the potential to impact opportunities for solitude, 

particularly if access is by motorized boat or floatplane, and use occurs in popular 

areas. Guided goat-hunting groups typically consist of one hunter and one or two 

guides. Occasionally two groups will camp together and hunt different areas. Due to 

the nomadic approach taken for goat hunting, and the small size of groups involved, 

the potential for visitor conflicts is minimal. Local hunters typically access high lakes 

in SBW for goat hunting in the early fall before guides begin conducting hunts, but 

there is some overlap in November. Access to herds is difficult and use tends to be 

concentrated at a few areas. Potential for conflicts exist at Lake Diana and Crawfish 

Inlet where both guided and unguided groups hunt. This has become more of an 

issue in recent years as hunting seasons have closed early due to more restrictive 

nanny harvest. Goat hunting guides have shifted their use patterns to earlier in the 

- 18 - 
season in order to be more assured of the opportunity to hunt with their clients.

Skills, Equipment, and 

Knowledge Required 

Visitors primarily access the SBW using motorized boats or float planes. Outfitters and 

guides can provide the skills, equipment, and knowledge required to safely access and 

enjoy the wilderness. The Alaska Department of Fish and Game (ADF&G) requires 

non-resident goat hunters to be accompanied by a registered guide or a relative within 

the second degree of kin. Goat hunting in Southeast Alaska is substantially different 

than hunting in other states. Hunters need to be skilled in identifying and stalking goats 

in a dynamic and challenging environment. It is also important that they understand how 

to identify males and females and are familiar with Guide Use Area boundaries 

identified by the State. A guide can ensure that State regulations and ethical hunting 

procedures are followed. 

Visitor Safety Southeast Alaska’s weather conditions and tidal fluctuations can be extreme throughout 

the year. Exposure to wind and cold weather poses a threat to visitor safety. Wildlife 

encounters, particularly with brown bear, also pose a risk to safety. Guides know how to 

track and retrieve animals, carry radios and/or satellite phones for communication, and 

carry back-up rifles in case of emergency. Mountain goat hunting is one of the most 

dangerous guided activities offered in Alaska. Hunts are typically carried out in very 

hazardous terrain where the risk of injury from slips, trips, and falls is substantial. 

Outfitter and Guide

Demand and Utilization

There are more requests for guided mountain goat hunting in SBW than can be 

accommodated. ADF&G has population concerns and authorized hunts have been kept 

at a low number. An average of 25 service days was reported annually for this activity 

(2008-2012). Existing authorizations are being fully utilized by guides. Most guides are 

booked years in advance for these hunts. 

Public Purposes & 

Special Management 

Objectives

Guided mountain goat hunting contributes to the recreational purpose of wilderness, 

although only a small segment of the population is willing or physically able to 

participate in this activity. Guides can help the ADF&G male to female harvest ratio 

objectives and ensure that hunters care for and process carcasses in accordance with 

State law. Guide hunt records also help track harvest locations and success rates, 

contributing to better management of goat populations. Guides can also teach clients 

about low-impact camping and hiking skills. 

Outfitter/guides provide access to mountain goat hunting opportunities in SBW that would otherwise be 

unavailable to those members of the general public interested in this activity because of the high level of 

knowledge, skills, and equipment needed to safely conduct a remote hunt. Outfitters and guides also help 

the Forest Service meet special management objectives for dispersing impacts related to nonresident 

harvest. Guides can help identify gender correctly, thereby limiting female harvest, which has been 

deemed critical by ADF&G for maintaining goat populations. This activity contributes to the recreational 

purpose of wilderness and has few resource concerns. These factors, along with the State of Alaska’s 

requirement for non-resident hunters to be accompanied by a licensed guide, indicate there is a need for 

outfitter/guide mountain goat hunting services in SBW. Guides can educate clients about low-impact 

camping and hiking skills to minimize impacts to the natural and undeveloped qualities of wilderness 

character.

Camping (including overnight use of public recreation cabins)

Camping is defined as overnight use within the wilderness. Daytime activities may involve boating or 

kayaking on marine waters or remote setting nature tours, hunting, or freshwater fishing within the 

wilderness. This use depends on sites amenable to camping such as level ground, accessible beach, 

availability of water, secure boat anchorage or storage, a food cache site, minimal signs of use by bears, 

and so on. 

- 19 - 
Table F5-6. Camping needs. 

Evaluation Criteria Evaluation of Need

Wilderness 

Dependence

Opportunities for guided camping exist in the non-wilderness portion of the Sitka 

Ranger District and surrounding areas of the Tongass National Forest. Wilderness, 

however, provides the remote wild land setting desired for this type of activity. 

Wilderness also provides an opportunity for guided visitors to practice Leave No 

Trace camping skills and learn about outdoor ethics. On non-wilderness NFS lands 

surrounding the SBW, there are relatively few high-elevation lakes available for 

camping and no high elevation public recreation cabins. There are several cabins 

on low-elevation lakes available outside of wilderness, including Baranof Lake, 

Sitkoh Lake, Kook Lake, and Lake Eva cabins. 

Wilderness Character Natural Quality: Guided camping generally occurs on the beaches along the shoreline of 

SBW and results in minimal impacts to vegetation, soil, and water resources. There are 

some locations where impacts to vegetation and soil are noticeable. Guided camping 

may increase the size of existing campsite boundaries. Firewood collection for 

campfires could occur, resulting in “human browse lines” or stumps. Stipulations for 

waste disposal and use of fire pans would have to be added to permits to ensure 

degradation of areas did not occur.

Outstanding Opportunities for Solitude or Primitive & Unconfined Recreation Quality: 

There is also a potential for guided groups to impact opportunities for solitude in the 

wilderness, particularly if the groups are large or use is authorized in popular locations 

(e.g., Red Bluff Bay). Many of the lakes in SBW are small and can only accommodate one 

group for camping. Along the adjacent waterways, motorized boat traffic has the 

potential to diminish opportunities for solitude. Use of public recreation cabins in SBW 

at Avoss, Davidof, and Plotnikof Lakes is low (on average 6-15 nights reserved per year), 

so competition is low. 

Skills, Equipment, and 

Knowledge Required 

Camping visitors primarily access the SBW using kayaks, motorized boats or float 

planes, including charter services. Outfitters may also provide camping equipment 

that visitors do not have. Outfitters and guides can provide the skills, equipment, 

and knowledge required to safely access and enjoy the wilderness. Many 

wilderness cabins are located in remote, steep basins and are not accessible by 

trail. Visitors may have limited experience in this type of terrain and weather 

conditions. Guides also provide the skills, equipment, and knowledge needed to 

minimize impacts from overnight visitors. Camping (including stays at remote 

wilderness public use cabins) involves skills that embrace traditional techniques 

and include elements of risk and challenge, especially for those new to the activity. 

It encourages self-reliance and helps strengthen independent decision-making. 

Visitor Safety Southeast Alaska’s weather conditions and tidal fluctuations can be extreme 

throughout the year. Exposure to wind and cold weather poses a threat to visitor 

safety. Wildlife encounters also pose a risk to safety. Outfitters and guides may 

provide communication with rescue services in the event of an emergency.

Outfitter and Guide 

Demand and Utilization

There is demand for guided camping services in the SBW. An average of 70 service 

days annually was reported for this guided activity (2008-2012). The beaches and 

high-elevation lakes in this wilderness provide desirable recreation settings for 

this type of activity. There have been no commercial use requests for fly-in, nonhunting related camping, with the exception of cabin camping, at any lakes in SBW. 

No permits have been issued for guided camping at public recreation cabins 

although interest has been expressed for this type of use. 

Public Purposes & 

Special Management 

Objectives

Guided camping tours provide an opportunity for the visiting public to safely 

access and enjoy the SBW for recreational pursuits. Multiple day experiences allow 

visitors to forge deep connections with nature. Outfitters and guides providing 

camping tours emphasize Leave No Trace skills and outdoor ethics. Campers often 

seek a wild land setting and this activity is consistent with the management of the 

area as wilderness. Forest Plan direction for public use cabins located in 

- 20 - 
wilderness is to maintain them at present or improved condition. However, high 

costs of maintenance for low-use cabins are becoming prohibitive. An opportunity 

exists for partnerships with guides to perform deferred maintenance on low-use 

cabins or provide firewood. Guides who pursue this activity could educate visitors 

on the use of primitive tools as well as the enabling legislation, which allows for 

these structures in wilderness. 

In summary, guided camping generally occurs on the beaches and along the shoreline of SBW and results 

in minimal impacts to vegetation, soil, and water resources. Wilderness provides an opportunity for 

guided visitors to practice traditional skills, learn about outdoor ethics, and forge deep connections with 

nature. Backcountry camping experiences depend on a wild land setting and are consistent with 

management of the area as wilderness. Outfitters and guides can provide area visitors with the skills, 

equipment, and knowledge required to safely access and enjoy the wilderness. There is a need for 

outfitter/guide camping services in SBW. 

There is a potential for guided groups to impact opportunities for solitude in the wilderness, particularly if 

the groups are large, use is authorized in popular locations (e.g., Red Bluff Bay), and access is via 

motorized transport. Group size will be limited to twelve in non-cabin locations and six to eight persons 

at cabins (depending on cabin capacity). Permit stipulations will be designed to reduce potential conflicts 

with unguided visitors. Preference will be given to operators that access the wilderness using nonmotorized transport, that promote Leave No Trace and outdoor ethics, and educate their clients about 

wilderness values.

Floatplane Landing Tours 

A floatplane landing tour is defined as a day-use activity that predominantly involves viewing natural 

features by air and landing once or multiple times within the wilderness and returning back to its point of 

origin. Visitors typically spend little time on land at each stop. Floatplane landing tours do not include 

authorized point-to-point floatplane transport used as an ancillary service to another commercial service 

for activities such as remote setting nature tours, hunting, fishing, or camping (including public use 

cabins).

Table F5-7. Floatplane Landing needs.

Evaluation Criteria Evaluation of Need

Wilderness 

Dependence

Floatplanes are a common and allowed method of transport for recreation use on 

the Tongass National Forest. However, the authorization of floatplane landing 

tours on the Tongass National Forest is limited and has not been authorized within 

the SBW. Misty Fiords National Monument provides a high number of service days 

for operators with lake landings. There are also several air taxi companies who 

provide this service without lake landings. In addition, several lakes exist outside 

of wilderness that offer sightseeing in a lake environment.

Wilderness Character Natural Quality: Visitors typically step off the plane and explore the nearby area on foot, 

spending a short amount of time in the wilderness before re-boarding the plane. As a 

result, these activities typically result in minimal impacts to vegetation, soil, and water 

resources; however the potential for vegetative damage and soil erosion exists. 

Potential resource concerns include repeated use on unprotected native tread (e.g., 

muskeg and forested wetlands), user-created trails and trail marking (e.g. flagging and 

rock cairns), particularly in areas with interesting features and recreation attractions. 

Undeveloped Quality: This activity is entirely dependent on the use of floatplanes. 

ANILCA Special Access provisions (Section 1110(a)) specifically allow for the continued 

use of airplanes for traditional activities and travel to and from villages and homesites. 

Recreation activities, such as sightseeing, are considered “traditional” as defined in 

Forest Service Manual 2326.1(6) (USDA Forest Service 2008a). As such, the presence of 

floatplanes in SBW is an accepted method of access and does not constitute a 

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degradation of the undeveloped quality of wilderness character. 

Outstanding Opportunities for Solitude or Primitive & Unconfined Recreation Quality: 

The frequency and duration of floatplane use can affect outstanding opportunities for 

solitude or primitive and unconfined recreation. Repeated landings at locations within 

wilderness by floatplane landing tour activities are not compatible with preserving 

these outstanding opportunities. The higher incidence of floatplane flights and landings 

that are associated with floatplane landing tours degrades the opportunities for those 

visitors seeking to experience the natural sounds of the wilderness and primitive 

recreation.

Skills, Equipment, and 

Knowledge Required 

Floatplane landing tours typically do not require a high degree of specialized skill, 

equipment or challenge for the forest visitor. Visitors typically step off the plane 

and explore the nearby area on foot, spending a short amount of time in the 

wilderness before re-boarding the plane. However, this activity does require an 

aircraft and pilot with experience in the challenging flying conditions of southeast 

Alaska. The average person would not have this equipment or skill and commercial 

services are typically needed for this activity.

Visitor Safety Any activity that exposes people to southeast Alaska’s wind, rain, and cold weather 

conditions poses a threat to visitor safety if visitors are unprepared. Wildlife 

encounters may also pose a risk to safety. Hazards that people could encounter 

include brown bears, sudden weather changes, uneven terrain, falls and 

hypothermia. Since the time spent out of the plane is relatively brief and groups 

typically stay close to the landing site, risk of hypothermia and exposure to the 

elements is low.

Outfitter and Guide 

Demand and Utilization

No outfitter/guides have been authorized for floatplane landing tours in SBW. 

There have been commercial use requests for this activity.

Public Purposes & 

Special Management 

Objectives

This activity predominantly involves viewing natural features from the air and 

landing for only short periods of time within the wilderness. The act of viewing the 

wilderness from an aircraft and spending relatively short periods of time on the 

ground, within the landscape and soundscape, represents an activity 

predominantly inhibited by modern civilization. Although floatplanes are an 

accepted method of access in SBW, the activity itself does not fulfill the purposes of 

wilderness that strives for invoking opportunities for spirituality and/or allow for 

deep connections with nature. 

In summary, floatplane landing tours do not offer opportunities for self-reliance and challenge to the 

wilderness visitor. This activity is entirely dependent on the use of aircraft to view the wilderness from 

the air with short periods of time on the ground. Although the method of access is allowed, the activity 

itself degrades outstanding opportunities for solitude or primitive types of recreation, and does not 

provide visitors the opportunity for developing deep connections with nature. There is not a need for 

outfitter/guide floatplane landing tour services in SBW.

Freshwater Fishing

Freshwater fishing includes both catch-and-take and catch-and-release methods under Alaska sport 

fishing regulations (excludes commercial and subsistence fishing). This use depends on places and times 

where anadromous and resident fish are located. 

Table F5-8. Freshwater Fishing needs. 

Evaluation Criteria Evaluation of Need

Wilderness 

Dependence

Several streams on non-wilderness NFS lands on the Sitka Ranger District and 

surrounding areas of the Tongass National Forest support anadromous fish 

populations and provide excellent freshwater fishing opportunities, including the 

Nakwasina, Salmon Lake, Lake Eva, Deer Lake, and Sashin Lake river systems. 

Opportunities for fishing on non-NFS lands are limited, but include Katlian Bay 

(Shee Atika Incorporated) and possibly State park areas. In addition to the lakes 

- 22 - 
mentioned previously, there are a limited number of nearby high-elevation lakes 

outside of the wilderness. Catch & release steelhead fishing is a guided activity that 

is desired throughout southeast Alaska and there are a limited number of primary 

steelhead streams available, three of which are in SBW (Politofski Lake Creek, Port 

Banks, and Sandy Bay Creek). 

Wilderness Character Natural Quality: Guided freshwater fishing is accessed via motorized boat or plane and 

results in minimal impacts to vegetation, soil, and water resources. Current resource 

concerns at streams include litter, development of “fishing paths,” and wildlife 

displacement. ADF&G provides sport fishing guidelines that help maintain the natural 

quality of wilderness character through the sustainable management of fish 

populations. 

Outstanding Opportunities for Solitude or Primitive & Unconfined Recreation Quality: 

Guided groups have the potential to impact opportunities for solitude, particularly if the 

groups are large and use is authorized in popular locations (e.g., Port Banks, Sandy Bay, 

Red Bluff Bay), or access is via motorized boat or floatplane. There is also potential for 

conflicts during spring and fall bear hunting seasons and subsistence fish harvest 

seasons (Table 1). Many of the lakes in SBW are small and can only accommodate one or 

two groups for fishing. Visitor conflicts may occur, particularly during steelhead, coho, 

and sockeye fishing seasons. 

Other Features of Value: 

Subsistence use has historically occurred in this wilderness area. Consideration will 

need to be made for subsistence users.

Brown Bear - There have been some reports of possible habituation of bears in sitespecific areas on the Sitka district (e.g. Port Banks, Red Bluff Bay).

Skills, Equipment, and 

Knowledge Required 

Visitors primarily access the SBW wilderness using motorized boats or float 

planes. Outfitters and guides can provide the skills, equipment, and knowledge 

required to safely access and enjoy the wilderness. Navigating and route-finding in 

steep, brushy terrain may also be beyond the skill level of many visitors. 

Outfitter/guides can impart knowledge of catch and release techniques, where and 

when the fish runs are occurring, fish identification, and proper disposal methods.

Visitor Safety Southeast Alaska’s weather conditions and tidal fluctuations can be extreme 

throughout the year. Exposure to wind and cold weather poses a threat to visitor 

safety. Wildlife encounters also pose a risk to safety.

Outfitter and Guide 

Demand and Utilization

There are numerous streams and low- and high- elevation lakes in SBW that 

support anadromous fishing populations. Between 2008 and 2012, 19 guides were 

authorized to provide guided freshwater fishing services in SBW and an average of 

244 service days were reported annually. The current level of use for fishing is low 

to high depending on the area and species. There is potential for conflicts as well, 

especially in fall and spring during guided bear hunts and during times of 

subsistence fish harvest (Falls Lake: June 1 – August 15; Gut Bay: July1 – July20; 

Necker: June 1 – August 31; Politofski: June 1 – July 31).

Public Purposes & 

Special Management 

Objectives

Guided freshwater fishing contributes to the recreational purpose of wilderness. 

Outfitter/guides promote proper catch and release techniques and an 

understanding of population dynamics in isolated streams and lakes. 

Outfitter/guides are required to turn in freshwater fishing logs to ADF&G; the 

results of these can be used to determine non-resident fishing harvest.

In summary, there are several streams and lakes in the SBW that provide outstanding remote freshwater 

fishing opportunities. Fishing is an appropriate use of wilderness and outfitter/guides contribute to the 

recreational purpose of wilderness. Guides can assist visitors by navigating and route-finding in steep, 

brushy terrain and teach low-impact practices. Guides also impart knowledge of catch and release 

techniques, where the runs are occurring, fish identification and proper disposal methods. There is a need 

for outfitter/guide freshwater fishing services in SBW. Preference will be given to outfitter/guides that 

- 23 - 
promote Leave No Trace and outdoor ethics and educate their clients about wilderness values. In addition, 

consideration will need to be made for subsistence users.

Remote Setting Nature Tours 

Remote setting nature tours encompass, but are not limited to, a wide variety of day use activities such as 

hiking, paddling, wildlife viewing, photography, exploring, sightseeing, and cultural tours. Visitors may 

spend a few minutes to many hours participating in these activities. Desirable attributes for these activities 

include accessible sections of shoreline, maintained trails and facilities, and unique features of geological, 

ecological, or cultural interest.

Table F5-9. Remote Setting Nature Tour needs. 

Evaluation 

Criteria

Evaluation of Need

Wilderness Dependence There are opportunities for guided remote setting nature tours (RSNT) on nonwilderness NFS lands on the Sitka Ranger District and surrounding areas of the Tongass 

National Forest. For example, lakes to the north and south of the wilderness can provide 

sightseeing and hiking opportunities at a lake environment. There are also outstanding 

hiking opportunities at Lake Eva, Kruzof Island, and Mist Cove. Guides currently offer 

tours in all of these areas. RSNT opportunities are limited on non-NFS lands; some 

opportunities exist at Katlian Bay (Shee Atika Incorporated), nearby State parks 

including an outstanding trail to Sea Lion Cove. Guides currently offer hikes in some of 

these non-NFS locations. 

However, wilderness provides the remote, wild land setting often desired for these 

activities. SBW in particular provides visitors the opportunity to learn about and 

experience the glacial features, geological features at Red Bluff Bay, brown bear, 

cultural history features, and rural Alaskan lifestyle that are unique to this wilderness. 

Wilderness Character • Natural Quality: RSNTs occurring in the SBW are primarily boat-based and use is 

generally concentrated on beaches and along established trails. It is rare that most 

visitors participating in RSNT travel more than one-half mile from shorelines unless 

there is an established trail. As a result, these activities typically result in minimal 

impacts to vegetation, soil, and water resources. However, potential resource 

concerns include repeated use on unprotected native tread (e.g., muskeg and 

forested wetlands), user-created trails and trail marking (e.g. flagging and rock 

cairns), particularly in areas with interesting features and recreation attractions. The 

potential for vegetative damage and soil erosion exists. 

• Outstanding Opportunities for Solitude or Primitive & Unconfined Recreation 

Quality: There is also a potential for outfitted/guided groups to impact opportunities 

for solitude in the wilderness, particularly if the groups are large, use is authorized in 

popular locations, or access is by motorized boat or float plane. Impacts to 

opportunities for solitude and primitive and unconfined recreation will be most 

noticeable in areas where visual screening from vegetation and topography is low. 

• Other Features of Value: 

o Brown Bear - There have been some reports of possible habituation of 

bears in site-specific areas on the Sitka district (e.g. Port Banks, Red Bluff 

Bay).

Skills, Equipment, and 

Knowledge Required 

Visitors primarily access the SBW using kayaks, motorized boats or float planes. 

Outfitters and guides can provide the skills, equipment, and knowledge required to 

safely access and enjoy the wilderness. Equipment for day hiking (e.g. rain gear, 

footwear, warm clothing) can be obtained at relatively inexpensive prices at stores 

nationwide. Air taxi services can drop off and pick up visitors at locations of their 

choice, but without local knowledge of the landscape, it may be difficult for a visitor to 

- 24 - 
identify suitable locations for this activity. Outfitters/ guides can provide the skills, 

equipment, and knowledge required to safely access the wilderness.

Visitor Safety While hiking and beach walking are simple skills, southeast Alaska’s weather 

conditions and tidal fluctuations can be extreme throughout the year. Exposure to wind 

and cold weather poses a threat to visitor safety if visitors are unprepared. Wildlife 

encounters may also pose a risk to safety. Hazards that people could encounter include 

brown bears, sudden weather changes, steep terrain, falls and hypothermia. Risk to 

safety and the physical and emotional challenges of surviving in this environment are 

high.

Outfitter and Guide 

Demand and Utilization

Twenty-three outfitter/guides were authorized to provide RSNTs in SBW between 2008 

and 2012. The most popular guided RSNT activity is hiking at Red Bluff Bay. Other 

consistently used locations include Gut Bay, Patterson Bay, Sandy Bay, and Port Banks. 

Most RSNT use occurs in the shoreline zone surrounding protected bays and beaches. 

Use of the uplands is low, but operators have expressed an interest in providing hiking 

tours in the upland portion of the wilderness from saltwater, as well as floatplane access 

to lakes.

Public Purposes & 

Special Management 

Objectives

Guided RSNTs provide an opportunity for the visiting public to safely access and enjoy 

SBW for recreational pursuits. Outfitters/guides providing RSNTs emphasize Leave No 

Trace skills and outdoor ethics. RSNTs depend on a wild land setting and are consistent 

with management of the area as wilderness. Guides authorized to operate in wilderness 

are required to educate clients about Leave No Trace outdoor ethics. For example, a 

guide could encourage clients to spread out in alpine and muskeg areas rather than walk 

single file. Additionally, an opportunity exists for partnerships with guides to perform 

deferred maintenance on low-use wilderness trails that are becoming cost-prohibitive to 

maintain.

Remote setting nature tours depend on a wild land setting and are consistent with management of the area 

as wilderness. There is a potential for guided groups to impact opportunities for solitude in the 

wilderness, particularly if the groups are large, use is authorized in popular locations (e.g., Red Bluff 

Bay), and access is via motorized boat or float plane. Guides can assist visitors by navigating and routefinding in steep, brushy terrain and teach low-impact practices. Outfitter/guides provide visitors with the 

skills, equipment, and knowledge required to safely access and enjoy the wilderness while still achieving 

a high level of self-reliance and challenge in the activity. There is a need for outfitter/guide remote setting 

nature tour services in SBW. Preference will be given to outfitter/guides that promote Leave No Trace 

and outdoor ethics, educate their clients about wilderness values, use smaller group sizes, and use nonmotorized transport. Permit stipulations will be designed to reduce potential conflicts with unguided 

visitors as well as minimize impacts to soils and vegetation.

Citations

ANILCA, 1980. Alaska National Interest Lands Conservation Act, Public Law 96-487, 96th Congress. 

USDA Forest Service, 2008a. Forest Service Manual, Alaska Region (Region 10), FSM 2300 – 

recreation, wilderness and related resource management, chapter 2320 – wilderness management. 

November 14, 2008. 

USDA Forest Service, 2008b. Tongass National Forest Land Resource and Management Plan. January 

2008. R10-MB-603b. 

- 25 - 
USDA Forest Service, 2007. Determination of Need and Extent of Commercial Uses within Wilderness 

Areas on the Tongass National Forest.

USDA Forest Service, 2004. Shoreline Outfitter/Guide Record of Decision and Final Environmental 

Impact Statement. December 2004. R10-MB-519a. 

Wilderness Act, 1964. Public Law 88-577. 19 U.S. C. 1131-1136. 88th Congress. 

- 26 - 
Appendix A. Management Direction

The Wilderness Act of 1964

The Wilderness Act of 1964 states the purpose of wilderness is “to secure for the American people of 

present and future generations the benefits of an enduring resource of wilderness.” Wilderness being an 

area “affected primarily by the forces of nature, with the imprint of man’s work substantially 

unnoticeable;” . . . “has outstanding opportunities for solitude or a primitive unconfined type of 

recreation; . . . and “may also contain ecological, geological, or other feature of scientific, educational, 

scenic, or historical value.” 

The Wilderness Act also describes how wilderness areas are to be used and managed. Management is to 

focus on preserving the wilderness character of the area; and use of the area “shall be devoted to the 

public purposes of recreational, scenic, scientific, education, conservation, and historical uses.” In 

realizing these uses wilderness provides an opportunity for solitude or primitive unconfined types of 

recreation not attainable in settings more man-made, or influenced by humans. 

In accomplishing the purpose of, and uses of wilderness, the Wilderness Act gives some additional 

direction. Specifically, with one notable exception commercial enterprises are prohibited by Section 4(c) 

of the Act. The exception covered in Section 4(d) (6) says; “commercial services may be performed 

within the wilderness area . . . to the extent necessary for activities which are proper for realizing the 

recreation or other wilderness purposes of the areas.” 

Alaska National Interest Lands Conservation Act of 1980 (ANILCA)

In 1990, the Tongass Timber Reform Act (TTRA) amended ANILCA and designated two new wilderness 

areas. Section 707 of ANILCA specifies that, “Except as otherwise expressly provided for in this Act, 

wilderness designated by this Act shall be administered in accordance with applicable provisions of the 

Wilderness Act ...” 

Items expressly provided for in ANILCA wilderness that apply to this assessment include:

(1) Section 811 – Reasonable access for subsistence resource uses.

(2) Section 1110(a) – Special Access allowing for the use of airplanes, motorboats, and snowmachines

(during periods of adequate snow) within conservation system units as defined by Section 102 (4).

These rights may be subject to reasonable regulation to protect the natural and other values of the

conservation system units.

(3) Section of 1303(b)(1) – Allowance for the construction of new cabins and administrative cabins if

necessary for the administration of the area as wilderness.

(4) Section 1307(b) – Provides a preference for providing visitor services (except for fishing and

hunting) within conservation system units to Native Corporations and local residents.

(5) Section 1315(c) – Allows for the permitting, maintenance, replacement, and continued use of

public use cabins.

(6) 1315(d) allows for the construction of new cabins if they are necessary for the protection of public

health and safety.

(7) Section 1316(a) – Allows for existing and future establishment of temporary structures necessary

for the taking of fish and game subject to reasonable regulation to insure compatibility, the

continuance of existing uses, and the future establishment, and use, of temporary campsites, tent

- 27 - 
platforms, shelters, and other temporary facilities and equipment directly and necessarily related to 

such activities. 

(8) Section 1316(b) allows for the denial of the temporary facilities if the use of equipment or facilities

is determined to be detrimental to the wilderness character.

ANILCA exceptions may influence the character of some wildernesses more than others. During the 

evaluation of commercial recreation use for any one wilderness, an effort should be made to consider the 

long-term effects of accommodating increasing uses or proposals for new use. The economic benefits to a 

business are not a substantive basis of a decision to allow use presented in either the Wilderness Act or 

ANILCA.

Direction Provided by Regulation

Federal Regulations 36 CFR 293.2 – Objectives, states in part: “Except as otherwise provided in the 

regulations..., National Forest wilderness shall be so administered as to meet the public purposes of

recreational, scenic, scientific, educational, conservation, and historical uses; and it shall also be 

administered for such other purposes for which it may have been established in such a manner as to 

preserve and protect its wilderness character...To that end:

(a) Natural ecological succession will be allowed to operate freely to the extent feasible.

(b) Wilderness will be made available for human use to the optimum extent consistent

with the maintenance of the primitive conditions.

(c) In resolving conflicts in resource use, wilderness values will be dominant to the extent

not limited by the Wilderness Act, subsequent establishing legislation, or the regulations in this

part.”

Federal Regulations 36 CFR 293.8 - Permanent structures and commercial services, states in part that: 

“The Chief, Forest Service, may permit . . . commercial services within National Forest wilderness to the 

extent necessary for realizing the recreational or other wilderness purposes, which include, but are not 

limited to, the public services generally offered by packers, outfitters, and guides.”

Forest Service Manual and Handbook Direction

Outfitters/guides must also meet agency objectives. These objectives are specifically outlined in the 

Forest Service Manuals (FSMs) and Forest Service Handbooks (FSHs). 

FSM 2702 Special Uses Management states: 

The objectives of the Special Uses program are to:

(1) Authorize and manage special uses of National Forest System lands in a manner which protects

natural resources and public health and safety, consistent with National Forest System Land and

Resource Management Plans;

(2) Administer special uses based on resource management objectives and sound business

management principles;

(3) Develop and maintain a well-trained workforce to properly manage and administer special uses;

and

(4) Facilitate the delivery of recreational opportunities on National Forest System lands for services

not provided by the Forest Service.

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(5) Forest Service Special Uses objectives specifically for outfitting and guiding, provided in FSH

2709.14, Chapter 50, Section 53.1b states:

1. Provide for outfitting and guiding services that address concerns of public health and

safety and that foster successful small businesses consistent with the applicable land

management plan.

2. Facilitate greater participation in the outfitting and guiding program by organizations

and businesses that work with youth and educational groups.

3. Encourage skilled and experienced individuals and entities to conduct outfitting and

guiding activities in a manner that protects environmental resources and ensures that

national forest visitors receive high-quality services.

Forest Service Special Uses policy for outfitting and guiding provided in FSH 2709.14, Chapter 50, 

Section 53.1c states: 

1. Authorize only those outfitting and guiding activities that are consistent with the applicable land

management plan and that meet the screening criteria in 36 CFR 251.54(e) and FSH 2709.11, chapter

10.

2. Not authorize any development or permanent improvements in non-wilderness in the National Forest

System for outfitting and guiding services, except when there is a demonstrated public need and the

structures, improvements, or installations have negligible value and minimal impact on national forest

resources, as with hitching posts, corrals, tent frames, permitted access routes, and shelters.

3. Not authorize any development, improvements, or installations in wilderness areas for the purpose of

convenience to the holder or the holder’s clients; caches in wilderness areas; and permanent

structures, improvements, or installations in wilderness areas unless they are necessary to meet

minimum requirements for administration of the area for the purposes of the Wilderness Act (16

U.S.C. 1133c).

4. Work with other Federal agencies, State and local authorities, outfitters and guides, outfitting and

guiding organizations, and other interested parties to ensure that outfitting and guiding activities are

consistent with applicable laws and regulations and to identify unauthorized outfitting and guiding

activities. Follow procedures in FSM 5300 in investigating and preventing the occurrence of

unauthorized outfitting and guiding activities.

Forest Service policy addressing outfitter and guide operations in wilderness found in FSM 2323.13g 

states that mangers should:

Address the need for and role of outfitters in the Forest Plan. The plan must address the type, 

number, and amount of recreation use that is to be allocated to outfitters. Ensure that outfitters provide 

their service to the public in a manner that is compatible with use by other wilderness visitors and that 

maintains the wilderness resource.

Objectives for wilderness management provided in FSM 2323.11 are to: 

1.Provide, consistent with management of the area as wilderness, opportunities for public use,

enjoyment, and understanding of the wilderness, through experiences that depend upon a wilderness

setting.

2. Provide outstanding opportunities for solitude or a primitive and unconfined type of recreation.

Forest Service policy addressing recreation management in wilderness in FSM 2323.12 states: 

1. Maximize visitor freedom within the wilderness. Minimize direct controls and restrictions. Apply

- 29 - 
controls only when they are essential for protection of the wilderness resources and after indirect 

measures have failed.

2. Use information, interpretation, and education as the primary tools for management of wilderness

visitors.

3. Manage for recreation activities that are dependent on the wilderness environment so that a

minimum of adaptations within wilderness are necessary to accommodate recreation.

4. Consistent with management as wilderness, permit outfitter/guide operations where they are

necessary to help segments of the public use and enjoy wilderness areas for recreational or other

wilderness purpose.

Tongass National Forest Land and Resource Management Plan Direction for 

Wilderness (pages 3-7 to 3-25)

Goals

To manage all designated wilderness to maintain an enduring wilderness resource while providing for 

public access and uses consistent with the Wilderness Act of 1964 and the Alaska National Interest Lands 

Conservation Act of 1980 (ANILCA). 

Protect and perpetuate natural biophysical and ecological conditions and processes. Ensure wilderness 

ecological systems are substantially free from the effects of modern civilization.

To provide a high degree of remoteness from the sights and sounds of humans, and opportunities for 

solitude and primitive recreation activities consistent with wilderness preservation.

Keep wilderness untrammeled and free from modern human control or manipulation, including actions 

taken to manage wilderness.

Protect the undeveloped character of wilderness by following legislative guidelines regarding permanent 

improvements or modern human occupation, including mechanized transport and motorized equipment. 

Objectives

Apply a multi-disciplinary focus to wilderness management. The stewardship of the wilderness is 

considered in the annual program of work by all resources.

Manage recreation activities so the levels of social encounters, on-site developments, methods of access, 

and visitor impacts indicated for the Primitive Recreation Opportunity Class are emphasized. Areas 

managed as semi-primitive within a wilderness are an exception and are not encouraged. 

Provide for public use of the wilderness in accordance with ANILCA provisions for motorized and nonmotorized access and travel, including reasonable traditional subsistence use by rural residents.

Maintain trails and primitive facilities that are in harmony with the natural environment and that promote 

primitive recreation opportunities. Feature facilities designed primarily to provide resource protection 

and encourage smaller group size. Facilities tend to allow for challenge and risk instead convenience. 

Maintain the wilderness capacity to provide information on natural ecological processes 

Preserve and perpetuate biodiversity 

Inventory, reduce, and when possible, eliminate non-native species in wilderness

Manage wilderness as a place where self-reliance and primitive skills are needed and can be honed. 

Desired Condition

All designated wilderness on the Tongass National Forest is characterized by extensive, unmodified 

natural environments. Ecological processes and natural conditions are not measurably affected by past or 

- 30 - 
current human uses or activities. Users have the opportunity to experience independence, closeness to 

nature, solitude and remoteness, and may pursue activities requiring self-reliance, challenge and risk. 

Motorized and mechanized use is limited to the minimum needed for the administration of the wilderness. 

Allow for access to state and private lands, subsistence uses, and for public access and other uses to the 

extent provided by ANILCA. If not specifically provided through an ANILCA exception, the resources 

within a designated wilderness shall be administered in accordance with the applicable provisions of the 

Wilderness Act.

The Forest Plan notes that; “Special Use Authorizations permitting individuals or organizations to provide 

visitor services in wilderness may be issued if there is a demonstrated need for the service(s) and they are 

deemed appropriate for the area proposed.”

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(USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and 

employees, and institutions participating in or administering USDA programs are 

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marital status, family/parental status, income derived from a public assistance 

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program or activity conducted or funded by USDA (not all bases apply to all 

programs). Remedies and complaint filing deadlines vary by program or incident. 

Persons with disabilities who require alternative means of communication for program 

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contact the responsible Agency or USDA’s TARGET Center at (202) 720-2600 (voice 

and TTY) or contact USDA through the Federal Relay Service at (800) 877-8339. 

To file a program discrimination complaint, complete the USDA Program 

Discrimination Complaint Form, AD-3027, found online at 

http://www.ascr.usda.gov/complaint_filing_cust.html and at any USDA office or write a 

letter addressed to USDA and provide in the letter all of the information requested in 

the form. To request a copy of the complaint form, call (866) 632-9992. Submit your 

completed form or letter to USDA by: (1) mail: U.S. Department of Agriculture, Office 

of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, 

Washington, D.C. 20250-9410; (2) fax: (202) 690-7442; or (3) email: 

program.intake@usda.gov . 

USDA is an equal opportunity provider, employer, and lender. 

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